IN THE UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

______ 

MATHEW SELOVER,

Plaintiff,

v. Case No.:

ESCAMBIA COUNTY BOARD

OF COMMISSIONERS, and 

RAYME EDLER,

Defendants. 

_________________________________

NOTICE OF REMOVAL

Pursuant to 28 U.S.C. §§ 1332, 1441, and 1446, Defendant, ESCAMBIA COUNTY 

BOARD OF COMMISSIONERS, (“Defendant” and/or “Escambia County”) through its 

undersigned counsel, hereby remove to this Court the instant action from the Circuit Court of the 

First Judicial Circuit in and for Escambia County, Florida, to the United States District Court for 

the Northern District of Florida. As grounds for removal Defendant states as follows:

1. The State Court action was commenced by Plaintiff, MATHEW SELOVER 

(“Plaintiff”), with the filing of his Complaint on January 17, 2020, in the Circuit Court of the 

First Judicial Circuit of Florida, Escambia County (Case No.: 2020-CA-000077).

2. Escambia County was served with the Complaint on February 11, 2020.

3. This Notice is filed within thirty (30) days after Service of the Complaint and 

Summons on the Defendant, in accordance with 28 U.S.C. § 1446(b). 

4. Undersigned counsel has conferred with counsel for Defendant, Rayme Edler, and 

Rayme Edler consents to removal. Undersigned counsel and Rayme Edler’s counsel have 

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entered into a joint stipulation for substitution of counsel in this matter and are awaiting the state 

court’s order granting same. 

5. The Action is properly removable pursuant to 28 U.S.C. §1441(a), which 

provides: 

Except as otherwise expressly provided by an Act of 

Congress, any civil action brought in a State court of which 

the district courts of the United States have original 

jurisdiction, may be removed by the defendant or the 

defendants, to the district court of the United States for the 

district and division embracing the place where such action is 

pending.

6. Here, the United States District Court has jurisdiction of the Action under 28 

U.S.C. § 1331, which provides: “The district shall have original jurisdiction of all civil actions 

arising under the Constitution, laws, or treaties of the United States.”

7. In Plaintiff’s Complaint, Plaintiff alleges that Defendant violated 42 U.S.C. § 

1983, U.S. Const. Amend. 14, and U.S. Const. Amend 1.

8. Pursuant to 28 U.S.C. § 1441(a), this Court is the proper forum for removal of the 

Action because it is the federal court for the district and division embracing the place where the 

state court suit is pending.

9. Pursuant to 28 U.S.C. § 1446(d), Plaintiff is being provided with written notice of 

the filing of this Notice of Removal.

10. Pursuant to 28 U.S.C. § 1446(d), a copy of this Notice of Removal is being filed 

with the Clerk of the Court for the Circuit Court of the First Judicial Circuit in and for Escambia

County, Florida. 

11. Pursuant to 28 U.S.C. § 1446(a) copies of all process, pleadings, papers, and 

orders served upon the Defendant in the Action are being provided to the Court with this Notice, 

attached hereto as Exhibit “A” through Exhibit “P”. 

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12. By filing this Notice of Removal, the Defendant does not intend to waive any 

available defenses; no admission of fact, law or liability is intended by this Notice of Removal, 

and all defenses, affirmative defenses and motions are hereby reserved.

WHEREFORE, Defendant, ESCAMBIA COUNTY BOARD OF COMMISSIONERS, 

hereby removes this case from the Circuit Court of the First Judicial Circuit in and for Escambia 

County, Florida, to the United States District Court for the Northern District of Florida, and 

respectfully request that the Court exercise jurisdiction over this matter and proceed with 

resolution of this case as if it had been originally filed herein.

Dated: March 11, 2020

LYDECKER | DIAZ

Attorneys for Defendant 

495 Grand Blvd, Suite 206

Miramar Beach, FL 32550

Telephone: (850) 269-6851

Facsimile: (850) 269-6801

 By: /s/ Stephanie Pidermann

STEPHANIE PIDERMANN, ESQ.

Florida Bar No: 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 11, 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/ Stephanie Pidermann

Stephanie Pidermann, Esq. 

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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

GEORGE F. INDEST III, J.D., M.P.A., LL.M.

THE HEALTH LAW FIRM

1101 Douglas Avenue, Suite 1000

Altamonte Springs, Florida 32714

P: GIndest@TheHealthLawFirm.com

S: CourtFilings@TheHealthLawFirm.com

S: CSchriefer@TheHealthLawFirm.com

S: LLeider@TheHealthLawFirm.com

S: AAggarwal@TheHealthLawFirm.com

Attorneys for Rayme Edler

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