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

(Circuit Court of the First Circuit, State of Hawaiʻi)

1. CAPTION

text
IN THE CIRCUIT COURT OF THE [FIRST/SECOND/THIRD/FIFTH] CIRCUIT
STATE OF HAWAIʻI

[PLAINTIFF_NAME],
Plaintiff,

v. Civil No. [CASE_NUMBER]
Judge: [JUDGE_NAME]
[DEFENDANT_NAME],
Defendant.

2. CERTIFICATE OF CONSULTATION

Pursuant to Rule 7.2 of the Rules of the Circuit Courts, undersigned counsel certifies that [he/she/they] conferred with counsel for [Non-Movant] on [DATE]. [Non-Movant] [does not oppose / opposes / takes no position].

3. MOTION

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

4. BASIS FOR REQUEST

1. The Court’s [order/minute order] dated [ORDER_DATE] set the deadline of [CURRENT_DEADLINE].
2. Since then, [Movant] has diligently [describe actions], including [FACT_DETAIL].
3. Additional time is required because [REASONS], despite due diligence.
4. The requested extension will not affect the trial date of [TRIAL_DATE] or other pretrial deadlines.

5. LEGAL STANDARD

Haw. R. Civ. P. 6(b) permits the Court to extend time for good cause when requested before expiration and for excusable neglect after expiration. Hawaiʻi courts favor adjudication on the merits when no undue prejudice results.

6. ARGUMENT

1. Good Cause. [Explain reasons for extension].
2. Diligence. [Describe efforts to comply].
3. Lack of Prejudice. Granting the extension will not prejudice [Non-Movant] and promotes efficient case management.

7. RELIEF REQUESTED

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

8. PROPOSED ORDER

text
IN THE CIRCUIT COURT OF THE [FIRST/SECOND/THIRD/FIFTH] CIRCUIT
STATE OF HAWAIʻI
Civil No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

The Court, having considered [Movant]'s Motion for Extension of Time and good cause appearing, hereby ORDERS that the motion is GRANTED.

[Movant] shall [describe act] on or before [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect unless otherwise ordered.

DATED: Honolulu, Hawaiʻi, ______, [YEAR].

Judge of the Above-Entitled Court

9. SIGNATURE BLOCK

text
DATED: Honolulu, Hawaiʻi, ______, [YEAR].

[LAW_FIRM_NAME]
[STREET_ADDRESS]
Honolulu, Hawaiʻi [ZIP]
Telephone: [PHONE]
Email: [EMAIL]

By: _____
[ATTORNEYNAME]
Hawaiʻi Bar No. [BAR_NUMBER]
Attorney for [MOVING_PARTY_NAME]

10. CERTIFICATE OF SERVICE

I hereby certify that on [SERVICE_DATE] the foregoing document was served via the Judiciary Electronic Filing and Service System (JEFS) and/or by [alternative method] on the following pursuant to Haw. R. Civ. P. 5(b):

[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.