State Court Motion for Extension of Time

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

(District Court, [COUNTY_NAME] County, Colorado)

1. CAPTION

DISTRICT COURT, [COUNTY_NAME] COUNTY, COLORADO
Court Address: [COURTHOUSE_ADDRESS]

Plaintiff: [PLAINTIFF_NAME],

v.                                                    Case No. [CASE_NUMBER]
                                                      Division: [DIVISION]
Defendant: [DEFENDANT_NAME].

2. CERTIFICATE OF COMPLIANCE

Pursuant to C.R.C.P. 121 § 1-15(8), undersigned counsel certifies that [he/she/they] conferred with counsel for [Non-Movant] on [DATE] regarding this motion. [Non-Movant] [does not oppose / opposes / takes no position].

3. MOTION

[Movant] respectfully moves, under C.R.C.P. 6(b), to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

4. GROUNDS

1. On [ORDER_DATE], the Court entered [describe order] establishing the current deadline.
2. [Movant] has diligently pursued [tasks], including [FACT_DETAILS], but requires additional time because [REASON_1], [REASON_2].
3. This request is made in good faith, is the first/second request, and is not intended to delay proceedings. Trial is set for [TRIAL_DATE], which will not be affected.

5. LEGAL AUTHORITY

C.R.C.P. 6(b)(1) allows the Court, for cause shown, to enlarge time when the request is made before the deadline, and to grant relief for excusable neglect after expiration. Courts evaluate diligence, reasonableness, and prejudice when determining good cause.

6. ARGUMENT

1. Good Cause/Excusable Neglect. [Detailed explanation of circumstances necessitating extension].
2. Diligence. [Summarize efforts already undertaken to comply with the original deadline].
3. No Prejudice. The extension will not prejudice [Non-Movant] because [reasons], and aligns with the Court’s scheduling order.

7. REQUESTED RELIEF

WHEREFORE, [Movant] requests that the Court extend the deadline for [describe act] to [PROPOSED_NEW_DEADLINE] and grant any further appropriate relief.

8. PROPOSED ORDER (ATTACHMENT)

DISTRICT COURT, [COUNTY_NAME] COUNTY, COLORADO
Case No. [CASE_NUMBER]
Division: [DIVISION]

[PLAINTIFF_NAME],
    Plaintiff,

v.

[DEFENDANT_NAME],
    Defendant.

            ORDER GRANTING MOTION FOR EXTENSION OF TIME

The Court, having reviewed [Movant]'s Motion for Extension of Time and finding good cause, ORDERS:

1. The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE].
2. [Optional] Related deadlines are modified as follows: [LIST].
3. All other deadlines remain as previously set.

DATED this ___ day of __________, [YEAR].

BY THE COURT:

__________________________________
[JUDGE_NAME]
District Court Judge

9. SIGNATURE BLOCK

Respectfully submitted this ___ day of __________, [YEAR].

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

By: __________________________________
    [ATTORNEY_NAME]
    Colorado Bar Reg. No. [BAR_NUMBER]
    Attorney for [MOVING_PARTY_NAME]

10. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed and served via the Colorado Courts E-Filing system to all counsel of record pursuant to C.R.C.P. 5(b). A copy was also served by [alternate 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.