UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CIVIL DIVISION

DEVIN FILIPPELLI as 

Personal Representative of the 

ESTATE OF KRYSTAL TALAVERA, CASE NO.: 9:22-cv-81731 

on behalf of the Estate and her Survivors, 

Plaintiff,

v. 

GROW, LLC (d/b/a KD INCORPORATED 

and THE KRATOM DISTRO); and SEAN 

MICHAEL HARDER, individually. 

Defendants. /

NOTICE OF FILING PROPOSED ORDER ON MOTION TO EXTEND THE 

DEADLINE TO JOIN ADDITIONAL PARTIES AND AMEND PLEADINGS

Plaintiff submits the Proposed Order Granting Plaintiff’s Motion to Extend 

the Deadline to Join Additional Parties and to Amend Pleadings. 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 17th day of January 2023, a true electronic 

copy of the foregoing was electronically filed with the Clerk of the Court using the 

CM/ECF system, and has been submitted to Defendants’ counsel, Bowman and 

Brooke LLP, Justin Niznik Esq., 1064 Greenwood Blvd. #212, Lake Mary, FL 32746, 

at:

justin.niznik@bowmanandbrooke.com; 

Case 9:22-cv-81731-DMM Document 21 Entered on FLSD Docket 01/17/2023 Page 1 of 4
orfa.diaz@bowmanandbrooke.com; and

kara.thomas@bowmanandbrooke.com.

_______________________________________________ 

Michael J. Cowgill, Esq. 

Florida Bar No. 1010945 

Tamara J. Williams, Esq. 

Florida Bar No. 127625 

mctlaw 

1605 Main Street, Suite 710 

Sarasota, FL 34236 

Telephone: 888.952.5242 

Facsimile: 941.952.5042 

Primary: mcowgill@mctlaw.com

Primary: twilliams@mctlaw.com

Secondary: hdiener@mctlaw.com

Secondary: mpowell@mctlaw.com

Attorneys for Plaintiff

Case 9:22-cv-81731-DMM Document 21 Entered on FLSD Docket 01/17/2023 Page 2 of 4
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CIVIL DIVISION

DEVIN FILIPPELLI as 

Personal Representative of the 

ESTATE OF KRYSTAL TALAVERA, CASE NO.: 9:22-cv-81731 

on behalf of the Estate and her Survivors, 

Plaintiff,

v. 

GROW, LLC (d/b/a KD INCORPORATED 

and THE KRATOM DISTRO); and SEAN 

MICHAEL HARDER, individually. 

Defendants. /

[PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION TO EXTEND 

THE DEADLINE TO JOIN ADDITIONAL PARTIES AND TO AMEND 

PLEADINGS

This matter is before the Court on the Motion to Extend the Deadline to Join 

Additional Parties and to Amend Pleadings filed herein by Plaintiff, DEVIN 

FILIPPELLI as Personal Representative of the ESTATE OF KRYSTAL TALAVERA, 

on behalf of the Estate and her Survivors.

Having considered all papers filed in connection with Plaintiff’s motion, the 

Court finds that it is appropriate to extend the deadline to amend pleadings and join 

additional parties.

Therefore, it is ORDERED AND ADJUDGED as follows:

1. Plaintiff’s motion is hereby GRANTED. 

Case 9:22-cv-81731-DMM Document 21 Entered on FLSD Docket 01/17/2023 Page 3 of 4
2. The deadline to join additional parties and amend pleading in the abovecaptioned case is extended to March 30, 2023.

DONE and ORDERED in Chambers this ______ day of ___________________, 

2023. 

__________________________________________

The Honorable Donald M. Middlebrooks 

United States District Court Judge 

Southern District of Florida 

Case 9:22-cv-81731-DMM Document 21 Entered on FLSD Docket 01/17/2023 Page 4 of 4