Plaintiffs’ 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 TO FILE JOINT REPORT

OF PARTY PLANNING MEETING

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

to enter an Order Granting an Extension of Time to File Joint Report of Party 

Planning Meeting [Doc.3]. In support of this motion, the parties state as follows:

1. Plaintiff filed his complaint on or about January 17, 2020 in Escambia 

County Circuit Court.

2. The Defendants removed the case to Federal Court on or about March 

3, 2020. [Doc.1].

3. The Initial Scheduling Order was entered on March 12, 2020. Per the 

Initial Scheduling Order, the parties are to have the conference of the 

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Plaintiffs’ Motion for Extension of time 

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parties within thirty (30) days from the date of the Order. Additionally, 

the parties are to file a joint report within fourteen (14) days thereafter. 

[Doc. 3].

4. The parties held the conference of the parties on April 13, 2020 and are 

almost finished with preparing the Joint Report of Party Planning 

Meeting. 

5. However, the parties need additional time to finalize the joint report.

6. Thus, parties respectfully request this Court to grant the parties an 

extension until Wednesday, April 29, 2020 to file the Joint Report of 

Party Planning Meeting. 

WHEREFORE, the above premises considered, the parties respectfully 

request this Court grant an extension of time to file the Joint Report of Party Planning 

Meeting, and grant any further such relief that is deemed just and proper.

/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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Plaintiffs’ 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 24th day of April, 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

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Plaintiffs’ Motion for Extension of time 

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imc@lydeckerdiaz.com

ev@lydeckerdiaz.com

Cecily L. Kaffer, Esq.

The Kullman Firm

P.O. Box 1287

Mobile, AL 36633

clk@kullmanlaw.com

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