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, Arkansas [JUDICIAL_CIRCUIT] Judicial Circuit)

1. CAPTION

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, ARKANSAS
[JUDICIAL_CIRCUIT] JUDICIAL CIRCUIT

[PLAINTIFF_NAME],
Plaintiff,

v. Case No. [CASE_NUMBER]

[DEFENDANT_NAME],
Defendant.

2. INTRODUCTION

Pursuant to Arkansas Rule of Civil Procedure 6(b), [Movant] respectfully moves the Court to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. BACKGROUND

1. On [ORDER_DATE], the Court issued [identify order] establishing the deadline of [CURRENT_DEADLINE].
2. [Movant] has diligently pursued [describe actions], including [FACT_1].
3. Additional time is needed because [FACT_2], despite reasonable efforts to comply.
4. Counsel conferred with [Opposing Counsel] on [MEET_DATE]; [Opposing Party] [consents/does not oppose/opposes] the requested extension.

4. LEGAL STANDARD

Under Ark. R. Civ. P. 6(b), the Court may enlarge deadlines for cause shown when the motion is filed before the original time expires, and upon excusable neglect after expiration. Arkansas courts favor deciding cases on their merits when no prejudice results.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain specific circumstances: e.g., "A key witness was unavailable due to hospitalization," "Recent supplemental discovery necessitates additional review."].
2. Diligence. [Describe actions taken promptly to comply with deadlines and steps undertaken during the current period.]
3. Lack of Prejudice. The requested extension will not prejudice [Non-Movant] because [reasons], and will not affect the trial date of [TRIAL_DATE] or other case deadlines.
4. Interests of Justice. Granting the extension promotes fairness, consistent with Ark. R. Civ. P. 1, by allowing the matter to be resolved on the merits.

6. REQUESTED RELIEF

WHEREFORE, [Movant] asks that the Court:
1. Extend the deadline for [describe act] to [PROPOSED_NEW_DEADLINE];
2. Adjust any dependent deadlines as appropriate; and
3. Award all other just and proper relief.

7. PROPOSED ORDER (ATTACHMENT)

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, ARKANSAS
[JUDICIAL_CIRCUIT] JUDICIAL CIRCUIT

[PLAINTIFF_NAME],
Plaintiff,

v. Case No. [CASE_NUMBER]

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

On this day the Court considered [Movant]'s Motion for Extension of Time. For good cause shown, the Motion is GRANTED.

The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain as previously set unless modified herein.

IT IS SO ORDERED this ___ day of ____, [YEAR].

[JUDGE_NAME]
Circuit Judge

8. SIGNATURE BLOCK

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

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

By: _____
[ATTORNEYNAME] (Ark. Bar No. [BAR_NUMBER])
Attorney for [MOVING_PARTY_NAME]

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] I filed the foregoing via the Arkansas Judiciary eFlex system, which provided notice to registered counsel pursuant to Ark. R. Civ. P. 5. I further served copies by [method] upon:

[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.