[COURT NAME]
[COUNTY], [STATE]
[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )
MOTION FOR LEAVE TO FILE [DOCUMENT NAME]
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 NAME] [OUT OF TIME/AS A SUPPLEMENTAL BRIEF].
MEMORANDUM OF POINTS AND AUTHORITIES
I. Introduction
Leave should be granted because [EXPLAIN GOOD CAUSE OR EXCUSABLE NEGLECT] and the proposed filing will aid the Court without prejudice to any party.
II. Background
- Relevant deadline or rule: [DEADLINE/RULE]
- Requested filing: [DOCUMENT NAME]
- Reason for delay or necessity: [REASON]
III. Legal Standard
Courts may grant leave to file documents out of time upon a showing of good cause or excusable neglect, and may allow supplemental briefing when it assists the Court and does not unfairly prejudice the opposing party.
IV. Argument
A. Good cause or excusable neglect exists.
[Explain diligence and circumstances.]
B. The requested filing will aid the Court and cause no prejudice.
[Explain why the filing is relevant and why any prejudice is minimal.]
V. Requested Relief
[MOVING PARTY] respectfully requests that the Court:
1. Grant leave to file [DOCUMENT NAME] attached as Exhibit A.
2. Set any response deadline deemed appropriate by the Court.
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].
text
______________________________
[ATTORNEY NAME]
[PROPOSED] ORDER
The Court, having considered the Motion for Leave to File, ORDERS as follows:
1. Leave to file [DOCUMENT NAME] is GRANTED.
2. Any response shall be filed by [DATE].
IT IS SO ORDERED.
Dated: [DATE]
__________________________________
[JUDGE NAME]
[STATE] Judge