Joint Motion for Extension of time 

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UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF FLORIDA

PENSACOLA DIVISION

MATHEW SELOVER

Plaintiff, 

vs. CASE NO.: 3:20-CV-4698-TKW-HTC

 

ESCAMBIA COUNTY BOARD

OF COUNTY COMMISSIONERS and

RAYME EDLER, 

Defendants.

JOINT MOTION FOR EXTENSION OF TIME OF DISCOVERY

The undersigned parties, by their respective counsel, hereby move this Court 

to enter an Order Granting an Extension of Time. In support of this motion, the 

parties state as follows:

1. Pursuant to the Scheduling and Mediation Order entered April 30, 2020, 

the discovery deadline is set for April 8, 2021. [Doc. 25].

2. Under the Scheduling and Mediation Order, Plaintiff’s expert 

disclosure deadline was set for January 8, 2021 and Defendants’ expert 

disclosure deadline was set for February 22, 2021. 

3. Since the entry of the Scheduling and Mediation Order, the parties have 

diligently conducted discovery.

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Joint Motion for Extension of time 

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4. The parties continue to cooperate with each other and diligently 

conduct discovery; however, because this case involves numerous 

parties, including a government entity which is governed by a five (5) 

member board of commissioners, and due to the COIVID-19 pandemic, 

the parties have had difficulty scheduling depositions, and are still 

coordinating same.

5. Thus, the circumstances necessitate an extension of the discovery and 

expert disclosure deadline, and all other deadlines dependent thereon. 

6. Accordingly, Plaintiff and the Defendants’ requests an extension of the 

discovery and expert disclosure deadline, and all other deadlines 

dependent thereon, by 45 days, respectively.

WHEREFORE, the above premises considered, the parties respectfully 

request this Court grant an extension of discovery.

/s/ JEREMIAH J. TALBOTT

JEREMIAH J. TALBOTT

Florida Bar No. 0154784

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

900 East Moreno Street

Pensacola, FL 32503

(850) 437-9600 

(850) 437-0906 (facsimile)

jjtalbott@talbottlawfirm.com

Attorney for Plaintiff

/s/ KATIE GUDAITIS___________

KATIE GUDAITIS

Florida Bar No. 106954

Lydecker Diaz

1221 Brickell Avenue, 19th Floor

Miami, FL 33131

(305) 416-3180

(305) 416-3190 (facsimile)

kg@lydeckerdiaz.com

Attorney for Defendant Escambia 

County Board of County Commissioners

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Joint Motion for Extension of time 

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/s/ CECILY L. KAFFER__________

CECILY L. KAFFER

Pro hac vice

Alabama Bar No. ASB-5953-R66C

The Kullman Firm

PO Box 1287

Mobile, AL 36633

(251) 378-2213

(251) 433-1230 (facsimile)

clk@kullmanlaw.com

Attorney for Defendant Rayme Edler

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 29th day of December, 2020 a true and 

correct copy of the foregoing Motion for Leave was furnished to counsel for the

Defendant as listed below via CMC/ECF, E-Mail and U.S. Mail.

/s/ Jeremiah J. Talbott

JEREMIAH J. TALBOTT, ESQ.

SERVICE LIST

Stephanie Pidermann, Esquire

Lydecker Diaz

1221 Brickell Avenue, 19th Floor

Miami, FL 33131

sp@lydeckerdiaz.com

kg@lydeckerdiaz.com

ksm@lydeckerdiaz.com

Ian M. Corp, Esq.

Lydecker Diaz

495 Grand Blvd, Suite 206

Miramar, FL 32550

imc@lydeckerdiaz.com

ev@lydeckerdiaz.com

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Cecily L. Kaffer, Esq.

The Kullman Firm

P.O. Box 1287

Mobile, AL 36633

clk@kullmanlaw.com

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