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IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

MATHEW SELOVER, 

 Plaintiff, 

v. Case No.: 3-20-CV-04698-TKW-HTC 

ESCAMBIA COUNTY BOARD 

OF COUNTY COMMISSIONERS; 

and RAYME EDLER, 

 Defendants. 

_________________________________/ 

DEFENDANT, ESCAMBIA COUNTY BOARD OF COUNTY 

COMMISSIONER’S, UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO RESPOND TO PLAINTIFF’S COMPLAINT 

Defendant, ESCAMBIA COUNTY BOARD OF COUNTY 

COMMISSIONERS (the “County Commissioners”), under Fed. R. Civ. P. 6(b), 

respectfully requests an extension of time up to and including March 30, 2020, to 

file an answer, motion, or other response to Plaintiff’s Complaint. 

1. Plaintiff filed his Complaint in the First Judicial Circuit Court of 

Florida, in and for Escambia County on January 17, 2020. 

2. The County Commissioners were served with process of this 

Complaint on February 21, 2020. 

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3. On March 11, 2020, the County Commissioners filed a Notice of 

Removal with this Court and with the First Judicial Circuit Court of Florida, in and 

for Escambia County to bring this case before this Court. D.E. 1. 

4. On March 23, 2020, the undersigned counsel conferred with counsel 

for the Plaintiff in good faith and requested an extension of time to respond to 

Plaintiff’s Complaint. Plaintiff’s counsel advised that they do not oppose an 

extension of time of seven (7) days to respond to the Complaint. 

5. This good faith request stems from the COVID-19 epidemic and the 

unexpected issues that the undersigned counsel has encountered as a result. 

6. Specifically, the undersigned counsel’s firm has been forced to

employ a mandatory work from home policy for all of its staff until and unless the 

State of Florida orders that it is safe for non-essential businesses to re-open. 

7. Given the substantial burden this unexpected network traffic imposed 

on the undersigned counsel’s firm’s servers due to its entire staff being logged onto 

its remote system simultaneously, undersigned’s firm was forced to procure 

additional resources to bolster its servers to allow all of its staff to work remotely 

from home simultaneously. 

8. Consequently, the undersigned counsel requested an extension of time 

to respond to the Complaint. 

9. Plaintiff’s counsel did not object to a seven (7) day extension of time. 

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10.Defendant’s counsel is in need of additional time to respond to the 

Complaint and confer with its client prior to formulating its response. 

11.Defendants respectfully request a seven-day extension of time to 

formulate its Response, which would make Defendant’s Response to the 

Complaint due on or before March 30, 2020. 

12.Under Fed. R. Civ. P. 6(b)(1), upon good cause, the Court may 

enlarge the period of time within which a defendant must serve its responsive 

pleading or motion. 

13.There is good cause for an extension of time to respond in this case 

because of the unexpected issues related to COVID-19 and undersigned requires 

additional time to speak with their client regarding the allegations raised in the 

Complaint. 

14.This motion is brought in good faith and not for the purposes of delay. 

15.Wherefore, for these reasons, Defendant, Escambia County Board of 

County Commissioners, respectfully requests that the Court enter an Order 

granting the Defendant an extension of time up to and including March 30, 2020, 

to file an answer, motion or otherwise respond to Plaintiff’s Complaint. 

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CERTIFICATION UNDER L.R. 7.1(B) 

Pursuant to Local Rule 7.1(B), I hereby certify that counsel for the movant 

has conferred with counsel for Plaintiff in a good faith effort to resolve the issues 

and Plaintiff has advised they do not oppose the extension of time. 

Dated: March 23, 2020. 

CERTIFICATION UNDER L.R. 7.1 (F)

Pursuant to Local Rule 7.1 (F), I hereby certify that the number of words in 

the Motion and Memorandum do not exceed 8,000 words. The total number of 

words is 488. 

Dated: March 23, 2020 

Respectively Submitted, 

LYDECKER | DIAZ 

Counsel for Escambia County 

495 Grand Blvd. 

Suite 206 

Miramar Beach, FL 

Telephone: (305) 416-3180 

 By: /s/ Katie Gudaitis 

 KATIE GUDAITIS, ESQ. 

 Florida Bar No: 106954 

 kg@lydeckerdiaz.com

STEPHANIE PIDERMANN, ESQ. 

FBN: 60414 

sp@lydeckerdiaz.com

CERTIFICATE OF SERVICE 

 I hereby certify that I electronically filed the foregoing document with the 

Clerk of Court using CM/ECF on March 23, 2020. I also certify that a true and 

correct copy of the foregoing was served this day via transmission of Notices of 

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Electronic Filing generated by CM/ECF on all counsel or parties of record on the 

Service List below. 

 /s/ Katie Gudaitis 

 Katie Gudaitis, Esq. 

SERVICE LIST

J.J. TALBOTT, ESQ. 

Law Office of Jerimiah J. Talbott, P.A. 

900 East Moreno Street 

Pensacola, Florida 32503 

jjtalbott@talbottlawfirm.com

Phone: (850) 437-9600 

Attorney for Plaintiff 

GEORGE F. INDEST, III, ESQ. 

THE HEALTH LAW FIRM 

1101 Douglas Avenue, Suite 1000 

Altamonte, Florida 32714 

gindest@thehealthlawfirm.com 

Phone: (407) 331-6620 

Attorneys for Rayme Edler

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