[COURT NAME]
[COUNTY], [STATE]
[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )
MOTION FOR EXTENSION OF TIME
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 an extension of time to [FILE DOCUMENT/RESPOND TO DISCOVERY] from [CURRENT DEADLINE] to [REQUESTED DEADLINE].
MEMORANDUM OF POINTS AND AUTHORITIES
I. Introduction
An extension is warranted because [GOOD CAUSE OR EXCUSABLE NEGLECT], and the request will not prejudice any party.
II. Background
- Current deadline: [DATE]
- Requested deadline: [DATE]
- Prior extensions: [NUMBER OR NONE]
- Position of opposing party: [OPPOSED/NOT OPPOSED]
III. Legal Standard
Courts may extend deadlines for good cause and, if the deadline has passed, upon a showing of excusable neglect. Relevant factors include diligence, reason for delay, and prejudice.
IV. Argument
A. Good cause exists for the requested extension.
[Explain reasons and diligence.]
B. The extension will not prejudice [OPPOSING PARTY].
[Explain limited impact on schedule.]
V. Requested Relief
[MOVING PARTY] respectfully requests that the Court:
1. Extend the deadline to [REQUESTED DEADLINE].
2. Adjust related deadlines as necessary.
CONCLUSION
For the foregoing reasons, the Court should grant the motion for extension of time.
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 Extension of Time on all counsel of record via [METHOD OF SERVICE].
text
______________________________
[ATTORNEY NAME]
[PROPOSED] ORDER
The Court, having considered the Motion for Extension of Time, ORDERS as follows:
1. The deadline to [FILE DOCUMENT/RESPOND TO DISCOVERY] is extended to [DATE].
2. Related deadlines are adjusted as necessary.
IT IS SO ORDERED.
Dated: [DATE]
__________________________________
[JUDGE NAME]
[STATE] Judge