0. ATTORNEY VALIDATION CERTIFICATE

I, [Attorney Name], certify that I have reviewed the current statutes, statewide procedural rules, and local rules governing deadline modifications in this matter on [REVIEW_DATE]; that the factual statements in this motion are accurate to the best of my knowledge; that applicable notice or conferral requirements have been satisfied or will be satisfied as represented below; and that I approve this motion for filing on behalf of [Client Name].

Signature: _____ Date: ___

Printed Name: _____ Bar No.: ____

MOTION FOR EXTENSION OF TIME

(In the Circuit Court of [COUNTY_NAME] County, Alabama)

1. CAPTION

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, ALABAMA
[CIVIL DIVISION]

[PLAINTIFF_NAME],
Plaintiff,

v. Case No. [CASE_NUMBER]

[DEFENDANT_NAME],
Defendant.

2. INTRODUCTORY NOTICE

COMES NOW [MOVING_PARTY_NAME], by and through undersigned counsel, and respectfully moves this Honorable Court pursuant to Rule 6(b) of the Alabama Rules of Civil Procedure to enlarge the time within which [he/she/they] must [identify required act, e.g., "serve responses to Plaintiff's First Set of Interrogatories"].

3. PROCEDURAL BACKGROUND

1. On [ORIGINAL_DEADLINE_DATE], [MOVING_PARTY_NAME] is presently required to [describe obligation].
2. The deadline arises from [cite order, rule, or agreement establishing deadline].
3. Undersigned counsel has conferred with counsel for [NONMOVING_PARTY_NAME] on [MEET_AND_CONFER_DATE], and [state opposing party's position: does not oppose / takes no position / opposes].

4. GROUNDS FOR RELIEF

1. Rule 6(b), Ala. R. Civ. P., authorizes the Court, for cause shown, to enlarge the period within which an act must be done upon a motion made before the expiration of the prescribed period, and upon excusable neglect when the motion is made thereafter.
2. Good cause exists for the requested enlargement because:
   - [FACT_1 explaining circumstances such as unexpected illness, discovery of voluminous records, ongoing settlement talks];
   - [FACT_2 detailing diligence, e.g., "Counsel has diligently pursued discovery but requires additional time to complete third-party subpoenas"];
   - [FACT_3 addressing absence of prejudice to the opposing party].
3. The requested extension is sought in good faith, is not interposed for the purpose of delay, and will not unduly prejudice any party. Trial is currently set for [TRIAL_DATE] and the requested adjustment will not impact existing pretrial deadlines or the trial setting.

5. REQUESTED RELIEF

WHEREFORE, [MOVING_PARTY_NAME] respectfully requests that the Court enter an order:
1. Extending the deadline for [identify act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE];
2. Granting such other and further relief as the Court deems just and proper.

6. PROPOSED ORDER (ATTACHMENT)

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, ALABAMA
[CIVIL DIVISION]

[PLAINTIFF_NAME],
Plaintiff,

v. Case No. [CASE_NUMBER]

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

Upon consideration of [Movant]'s Motion for Extension of Time and for good cause shown, it is ORDERED that the motion is GRANTED.

The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect unless modified by the Court.

DONE and ORDERED this ___ day of ____, [YEAR].

[JUDGE_NAME]
Circuit Judge

7. SIGNATURE BLOCK

text
Respectfully submitted this ___ day of ____, [YEAR].

[LAW_FIRM_NAME]
[STREET_ADDRESS]
[City], Alabama [ZIP]
Telephone: [PHONE]
Email: [EMAIL]

By: ______
[ATTORNEY_NAME] (ASB-__)
Attorney for [MOVING_PARTY_NAME]

8. CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ____, [YEAR], I electronically filed the foregoing via AlaFile which will serve all registered counsel of record pursuant to Ala. R. Civ. P. 5. Alternatively, I served a copy upon the following by [method]:

[ATTORNEY_NAME]

11. SAMPLE GOOD CAUSE NARRATIVE (TAILOR BEFORE FILING)

On March 12, 2024, [Movant] received 3,400 pages of supplemental records from a third-party provider. The materials revealed new witnesses and data points requiring expert analysis. [Movant] immediately retained the appropriate expert, who was first available on [EXPERT_MEETING_DATE], and coordinated with opposing counsel to schedule any follow-up discovery. Absent a short extension of the current [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE], [Movant] cannot incorporate the new information into required submissions. Opposing counsel was contacted on [CONFERRAL_DATE] but declined to stipulate, identifying no concrete prejudice beyond a preference to maintain the existing schedule.

12. MITIGATION COMMITMENT TEMPLATE

1. Maintain the existing trial or dispositive motion dates unless the Court directs otherwise.
2. Produce all outstanding discovery or supplemental disclosures no later than [COMMITMENT_DATE].
3. Offer supplemental deposition or interview availability for affected witnesses during [DATE_RANGE] at [LOCATION].
4. Provide a status update letter to the Court and opposing counsel within [STATUS_UPDATE_WINDOW] days of the new deadline.