IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

PENSACOLA DIVISION

MATHEW SELOVER,

Plaintiff,

v. Case No.:3:20cv4698-

TKW/HTC

ESCAMBIA COUNTY BOARD

OF COMMISSIONERS, and 

RAYME EDLER,

Defendants. 

_________________________________

DEFENDANT, ESCAMBIA COUNTY BOARD

OF COMMISSIONERS’S UNOPPOSED MOTION FOR EXTENSION OF 

TIME TO 

RESPOND TO THE AMENDED COMPLAINT

Defendant, ESCAMBIA COUNTY BOARD OF COMMISSIONERS 

(“Defendant”) pursuant to Fed. R. Civ. P. 6(b) respectfully request an extension of 

time up to and including May 15, 2020, to file an answer, motion, or other 

response to Plaintiff’s Amended Complaint (“Complaint”) [DE 20]. In support of 

this motion, Defendants state as follows:

1. Plaintiff filed his Amended Complaint on April 23, 2020, therefore a 

response would be due on or before May 6, 2020. 

Case 3:20-cv-04698-TKW-HTC Document 26 Filed 05/06/20 Page 1 of 4
2

2. Defendant requests additional time for which to formulate a response 

to the Complaint. 

3. Pursuant to 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. 

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

because counsel for Defendant needs additional time to speak with their clients and 

more fully investigate the allegations contained in Plaintiff’s Complaint.

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

Further, this action was only recently filed. Thus, the enlargement of time 

requested by Defendant will not prejudice the Court or the parties. 

6. For the aforesaid reasons, Defendant, ESCAMBIA COUNTY 

BOARD OF COMMISSIONERS, respectfully request that the Court enter an 

Order granting the Defendant an extension of time up to and including May 15, 

2020 to file an answer, motion, or otherwise respond to Plaintiff’s Amended 

Complaint [DE 20].

Certification of Good Faith

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: May 6, 2020

Case 3:20-cv-04698-TKW-HTC Document 26 Filed 05/06/20 Page 2 of 4
3

LYDECKER | DIAZ

Attorneys for Defendant 

495 Grand Blvd, Suite 206

Miramar Beach, FL 32550

Telephone: (850) 269-6851

Facsimile: (850) 269-6801

 By: /s/ Katherine Gudaitis

KATHERINE GUDAITIS, ESQ.

Florida Bar No: 106954

kg@lydeckerdiaz.com

CERTIFICATE OF SERVICE

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

Clerk of Court using CM/ECF on May 6, 2020. I also certify that a true and correct 

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

JEREMIAH J. TALBOTT, ESQ.

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

900 E. Moreno Street 

Pensacola, FL 32503

PIE:jjtalbott@talbottlawfirm.com

S/E:civilfilings@talbottlawfirm.com

Phone: (850) 434-9200

Attorneys for Plaintiff

CECILY L. KAFFER, ESQ.

Pro Hac Vice

The Kullman Firm

Post Office Box 1287

Mobile, Alabama 36633

P: clk@kullmanlaw.com

T: 251) 432-1811

Attorney for Rayme Edler

Case 3:20-cv-04698-TKW-HTC Document 26 Filed 05/06/20 Page 3 of 4
4

Case 3:20-cv-04698-TKW-HTC Document 26 Filed 05/06/20 Page 4 of 4