No Added Time For Mailing

When a court orders that a matter be done by a certain date, do the parties get to add an additional five days for mailing pursuant to Rule 2.514? The First DCA took a detailed look at the issue and determined that, when a deadline is set by court order, no additional time is available unless specified by the court:

[W]hen a court orders that a document be filed by a “date certain” or “even by reference to a specified number of days from a date noted in the order,” the additional time afforded by rule 2.514(b) is unavailable.

C.M. v. Dep’t of Children and Families, CASE NO. 1D16-4711, (1st DCA Feb. 16, 2017).