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 Superior Court of the State of Delaware in and for [COUNTY_NAME] County)

1. CAPTION

text
IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR [COUNTY_NAME] COUNTY

[PLAINTIFF_NAME],
Plaintiff,

v. C.A. No. [CASE_NUMBER]
Submitted: [SUBMISSION_DATE]
[DEFENDANT_NAME], Judge: [JUDGE_NAME]
Defendant.

2. MOTION

[Movant], by and through undersigned counsel, respectfully moves pursuant to Superior Court Civil Rule 6(b) for an extension of time to [describe act], currently due on [CURRENT_DEADLINE], and requests a new deadline of [PROPOSED_NEW_DEADLINE].

3. GROUNDS FOR RELIEF

1. On [ORDER_DATE], the Court issued [identify order] setting the deadline at issue.
2. [Movant] has diligently [describe actions], including [FACT_DETAILS].
3. Additional time is needed because [REASONS], despite the exercise of reasonable diligence.
4. [Non-Movant] [consents / does not oppose / opposes] this motion. Counsel conferred on [DATE].

4. LEGAL STANDARD

Rule 6(b) authorizes the Court, for cause shown, to enlarge the period within which an act must be done, and after expiration upon a showing of excusable neglect. Delaware courts evaluate diligence, length of delay, prejudice, and the interest of justice.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Detail circumstances supporting the extension].
2. Diligence. [Explain steps taken to comply with the schedule].
3. No Prejudice. The requested extension will not prejudice [Non-Movant] because [reasons]; trial remains set for [TRIAL_DATE] and no other milestones are affected.

6. REQUESTED RELIEF

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

7. PROPOSED ORDER (ATTACHMENT)

text
IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR [COUNTY_NAME] COUNTY
C.A. 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, it is hereby ORDERED that the motion is GRANTED.

[Movant] shall [describe act] on or before [PROPOSED_NEW_DEADLINE]. All other provisions of the Case Scheduling Order remain unchanged.

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

Judge [JUDGE_NAME]

8. SIGNATURE BLOCK

text
Dated: ______, [YEAR]

[LAW_FIRM_NAME]
[STREET_ADDRESS]
[City], Delaware [ZIP]
Tel: [PHONE]
Email: [EMAIL]

By: _____
[ATTORNEYNAME] (Bar I.D. No. [BAR_NUMBER])
Attorneys for [MOVING_PARTY_NAME]

9. CERTIFICATE OF SERVICE

I hereby certify that on [SERVICE_DATE] a true and correct copy of the foregoing was electronically served via File & ServeXpress upon all registered counsel pursuant to Super. Ct. Civ. R. 5(b). Copies were also served by [method] on:

[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.