[COURT NAME]
[DIVISION] DIVISION

[PLAINTIFF NAME(S)], §
§
Plaintiff[s], §
§ CIVIL ACTION NO. [CASE NO.]
v. §
§
[DEFENDANT NAME(S)], §
§
Defendant[s]. §
________________________________________________§______________________________________________

[MOVING PARTY] MOTION FOR LEAVE TO FILE [DOCUMENT]
________________________________________________________________________________________________

[// GUIDANCE: Insert any required local-rule header language here.]

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court for leave to file [DOCUMENT] pursuant to [RULE/ORDER].

This Motion is based on the accompanying memorandum, declarations, the proposed [DOCUMENT] attached as Exhibit [__], the pleadings on file, and such other argument or evidence as may be presented.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

[Briefly explain what is being filed and why leave is required.]

II. Background

• Case schedule and relevant deadlines: [DATES].
• Prior extensions or related motions: [LIST].

III. Legal Standard

[State the governing standard for the rule invoked (e.g., good cause, excusable neglect, interests of justice).]

IV. Argument

A. Good cause exists to grant leave.
[Explain diligence and reasons beyond the party's control.]

B. No prejudice to opposing party.
[Explain lack of prejudice or how any prejudice can be mitigated.]

C. The request is in good faith.
[Explain reasonableness and need for the filing.]

V. Requested Relief

[MOVING PARTY] respectfully requests that the Court grant leave to file the proposed [DOCUMENT] attached as Exhibit [__] and deem it filed as of the date of the Court's order.

CONCLUSION

For the foregoing reasons, the Court should grant the Motion for Leave to File.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion for Leave to File on all counsel of record via [METHOD OF SERVICE] in compliance with Fed. R. Civ. P. 5.

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered [MOVING PARTY]'s Motion for Leave to File, ORDERS as follows:
1. The Motion is GRANTED.
2. [MOVING PARTY] may file the [DOCUMENT] attached as Exhibit [__] within [NUMBER] days.

IT IS SO ORDERED.

Dated: [DATE]

______________________________________
[JUDGE NAME]
United States District Judge