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 the [JUDICIAL_CIRCUIT] Judicial Circuit, in and for [COUNTY_NAME] County, Florida)

1. CAPTION

text
IN THE CIRCUIT COURT OF THE [JUDICIAL_CIRCUIT] JUDICIAL CIRCUIT
IN AND FOR [COUNTY_NAME] COUNTY, FLORIDA

[PLAINTIFF_NAME],
Plaintiff,

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

2. CERTIFICATE OF CONFERRAL

Undersigned counsel certifies that [he/she/they] conferred with counsel for [Non-Movant] on [DATE] regarding this motion. [Non-Movant] [agrees / does not oppose / opposes] the relief requested.

3. MOTION

[Movant], through undersigned counsel, moves pursuant to Fla. R. Civ. P. 1.090(b) for an extension of time to [describe act], presently due on [CURRENT_DEADLINE]. [Movant] seeks an extension until [PROPOSED_NEW_DEADLINE].

4. FACTUAL BACKGROUND

1. The Court’s [order/scheduling directive] dated [ORDER_DATE] set the deadline at issue.
2. [Movant] has diligently [describe actions], including [FACT_DETAIL].
3. Despite diligence, additional time is necessary because [REASONS], constituting good cause/excusable neglect.
4. The requested extension will not impact the trial date of [TRIAL_DATE] or other pretrial deadlines.

5. LEGAL STANDARD

Rule 1.090(b) authorizes enlargement of time for good cause before the period expires, and for excusable neglect afterward. Courts evaluate diligence, length of delay, prejudice, and the administration of justice. See, e.g., Goldman v. State Farm, 660 So. 2d 300 (Fla. 4th DCA 1995).

6. ARGUMENT

1. Good Cause/Excusable Neglect. [Detail supporting facts].
2. Diligence and Minimal Delay. [Describe efforts and limited nature of requested extension].
3. Lack of Prejudice. [Explain absence of prejudice and benefit to orderly case management].

7. REQUESTED RELIEF

WHEREFORE, [Movant] respectfully requests that the Court extend the deadline for [describe act] to [PROPOSED_NEW_DEADLINE], modify related deadlines as appropriate, and grant such other relief as may be just.

8. PROPOSED ORDER (ATTACHMENT)

text
IN THE CIRCUIT COURT OF THE [JUDICIAL_CIRCUIT] JUDICIAL CIRCUIT
IN AND FOR [COUNTY_NAME] COUNTY, FLORIDA
Case 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 good cause appearing, it is ORDERED:

1. The motion is GRANTED.
2. The deadline for [describe obligation] is extended to [PROPOSED_NEW_DEADLINE].
3. All other deadlines remain unchanged unless otherwise specified.

DONE AND ORDERED in Chambers at [CITY], [COUNTY_NAME] County, Florida this ___ day of ____, [YEAR].

Circuit Judge

9. SIGNATURE BLOCK

text
Respectfully submitted,

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

By: ______
[ATTORNEY_NAME]
Florida Bar No. [BAR_NUMBER]
Counsel for [MOVING_PARTY_NAME]
Dated: ____, [YEAR]

10. CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served on [SERVICE_DATE] via the Florida Courts E-Filing Portal pursuant to Fla. R. Gen. Prac. & Jud. Admin. 2.516(b), which furnished electronic service to all counsel of record, and by [additional 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.