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 NUMBER: 3:20-CV-4698-

TKW-HTC

 

ESCAMBIA COUNTY BOARD

OF COUNTY COMMISSIONERS and

RAYME EDLER, 

Defendants.

 /

PLAINTIFF’S UNOPPOSED MOTION 

FOR EXTENTION OF TIME TO RESPOND TO DEFENDANTS’, 

ESCAMBIA COUNTY BOARD OF COUNTY COMMISSIONERS AND 

RAYME EDLER (IN HER OFFICIAL CAPACITY), MOTION TO DISMISS 

COUNTS I, III, AND V OF PLAINTIFF’S COMPLAINT

COMES NOW, the Plaintiff, MATHEW SELOVER, by and through the 

undersigned counsel hereby moves this Court for an extension of time to file 

Plaintiff’s Response to Defendants’, Escambia County Board of County 

Commissioners and Rayme Edler (in her official capacity) (collectively referred to 

as the Board), Motion to Dismiss Counts I, III and V of Plaintiff’s Complaint and 

Memorandum of Law (the Motion to Dismiss). In support of this motion, the 

Plaintiff states as follows:

1. Plaintiff filed this case on or about January 17, 2020 in Escambia 

Case 3:20-cv-04698-TKW-HTC Document 13 Filed 04/09/20 Page 1 of 4
Plaintiffs’ Motion for Extension of time 

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County Circuit Court.

2. The Defendants removed the case to this Court on or about March 3, 

2020. [ECF No. 1].

3. After removal, the Board sought an extension on the time to file an 

Answer until March 30, 2020, which Plaintiff’s counsel did not oppose, 

and which the Court granted. [ECF No. 5].

4. Then, on or about March 30, 2020, the Board filed the Motion to 

Dismiss. 

5. Plaintiff’s response to the Board’s Motion to Dismiss is due on April 

13, 2020. 

6. As the Court is aware, as a result of the COVID19 pandemic, the State 

of Florida is under a stay at home order, and many in the legal 

profession, including Plaintiff’s counsel are working remotely. 

7. As a result of these circumstances, Plaintiff’s counsel needs additional 

time to respond to the Motion to Dismiss and confer with Plaintiff prior 

to formulating the response. 

8. Thus, Plaintiff respectfully requests this Court grant Plaintiff a ten (10) 

day extension to respond to the Board’s Motion to Dismiss, making the 

deadline Thursday, April 23, 2020.

9. This motion is made in good faith, and not for the purposes of delay. 

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Plaintiffs’ Motion for Extension of time 

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Further, the short time extension requested herein will not prejudice the 

Defendants. 

10. Plaintiff’s counsel has conferred with the Board’s counsel regarding the 

relief requested herein, and the Board’s counsel has confirmed in 

writing that the Board DOES NOT OBJECT to the short time extension

requested herein. 

WHEREFORE, the Plaintiff, MATHEW SELOVER, respectfully requests

this Court grant the Plaintiff a ten (10) day extension to respond to the Board’s

Motion to Dismiss, making the deadline Thursday, April 23, 2020.

Respectfully submitted,

/s/ Travis P. Lampert

JEREMIAH J. TALBOTT, ESQ.

Florida Bar No. 0154794

TRAVIS P. LAMPERT, ESQ. 

Florida Bar No. 0099843

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

900 East Moreno Street

Pensacola, FL 32503

(850) 437-9600 / (850) 437-0906 (facsimile)

Attorneys for Plaintiff

jjtalbott@talbottlawfirm.com

civilfilings@talbottlawfirm.com

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(B)

I HEREBY CERTIFY that the undersigned has complied with Local Rule 

7.1(B), and the Board’s counsel has advised there is NO OBJECTION to the relief 

requested above. 

/s/ Travis P. Lampert

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Plaintiffs’ Motion for Extension of time 

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TRAVIS P. LAMPERT, ESQ.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 9th day of April, 2020 a true and correct 

copy of the foregoing Response was furnished to counsel for the Defendants as listed 

below via CMC/ECF.

/s/ Travis P. Lampert

TRAVIS P. LAMPERT, 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

George F. Indest, III, Esq.

Carole C. Schriefer, Esq.

Lance O. Leider, Esq. 

Achal A. Aggarwal, Esq.

The Health Law Firm

1101 Douglas Avenue, Suite 1000

Altamonte Springs, FL 32714

GIndest@TheHealthLawFirm.com

CourtFiling@TheHealthLawFirm.com

CSchriefer@TheHealthLawFirm.com

LLeider@TheHealthLawFirm.com

AAggarwal@TheHealthLawFirm.com

Cecily L. Kaffer, Esq.

The Kullman Firm

P.O. Box 1287

Mobile, AL 36633

clk@kullmanlaw.com

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