State Court Motion for Extension of Time
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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

(Superior Court of the District of Columbia, Civil Division)

1. CAPTION

text
SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION

[PLAINTIFF_NAME],
Plaintiff,

v. Civil Action No. [CASE_NUMBER]
Calendar [CALENDAR]
[DEFENDANT_NAME], Judge [JUDGE_NAME]
Defendant.

2. RULE 12-I CERTIFICATE

Pursuant to Super. Ct. Civ. R. 12-I(a), undersigned counsel certifies that [he/she/they] conferred with counsel for [Non-Movant] on [DATE] regarding the relief sought. [Non-Movant] [consents / does not oppose / opposes] this motion.

3. MOTION

[Movant] respectfully moves the Court under Super. Ct. Civ. R. 6(b) to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

4. FACTUAL SUPPORT

  1. On [ORDER_DATE], the Court set [CURRENT_DEADLINE] for [obligation].
  2. Since that order, [Movant] has diligently [describe actions], including [FACT_DETAILS].
  3. Additional time is necessary because [REASONS], despite reasonable diligence.
  4. The requested extension will not affect the current trial or scheduling order dated [SCHED_ORDER_DATE].

5. LEGAL STANDARD

Super. Ct. Civ. R. 6(b) authorizes the Court to enlarge the period for performing an act for good cause when sought before expiration, or for excusable neglect afterward. Compliance with Rule 12-I is mandatory.

6. ARGUMENT

  1. Good Cause/Excusable Neglect. [Provide detailed explanation supporting the extension].
  2. Diligence. [Explain efforts undertaken promptly to meet the original deadline].
  3. Absence of Prejudice. [Describe why non-movant will not be prejudiced and how the extension promotes justice].

7. REQUEST FOR RELIEF

WHEREFORE, [Movant] requests that the Court extend the deadline for [describe act] to [PROPOSED_NEW_DEADLINE] and grant such further relief as is just.

8. PROPOSED ORDER (ATTACHMENT)

text
SUPERIOR COURT OF THE DISTRICT OF COLUMBIA
CIVIL DIVISION
Civil Action No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

Upon consideration of [Movant]'s Motion for Extension of Time and the entire record herein, it is this ___ day of ____, [YEAR], ORDERED that the motion is GRANTED.

The deadline for [describe obligation] is extended to [PROPOSED_NEW_DEADLINE]. All other dates remain in effect.

SO ORDERED.


Judge [JUDGE_NAME]
Superior Court of the District of Columbia

9. SIGNATURE BLOCK

text
Respectfully submitted,

[LAW_FIRM_NAME]
[STREET_ADDRESS]
Washington, DC [ZIP]
Tel: [PHONE]
Email: [EMAIL]

By: ______
[ATTORNEY_NAME] (D.C. Bar No. [BAR_NUMBER])
Counsel for [MOVING_PARTY_NAME]
Dated:
____, [YEAR]

10. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] I filed the foregoing via CaseFileXpress, which sent notice to all counsel of record pursuant to Super. Ct. Civ. R. 5(b)(1). Copies were also served by [alternate method] upon:

Name Address/Email Method
[RECIPIENT_NAME] [CONTACT_INFORMATION] [SERVICE_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.
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