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 Iowa District Court for [COUNTY_NAME] County)

1. CAPTION

text
IN THE IOWA DISTRICT COURT FOR [COUNTY_NAME] COUNTY
Case No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves under Iowa Rule of Civil Procedure 1.902(4) to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. GROUNDS

1. The Court’s [order/scheduling order] entered on [ORDER_DATE] set the deadline at issue.
2. [Movant] has diligently [describe actions], including [FACT_DETAIL].
3. Additional time is necessary because [REASONS], despite the exercise of due diligence.
4. Counsel conferred with [Opposing Counsel] on [DATE]; [Opposing Party] [consents / does not oppose / objects].

4. LEGAL STANDARD

Rule 1.902(4) authorizes the Court to enlarge time for good cause. When filed after expiration, a showing of excusable neglect is required. Courts consider diligence, prejudice, and impact on the schedule.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain reasons supporting relief].
2. Diligence. [Detail efforts made to comply with the deadline].
3. No Prejudice. Granting the extension will not prejudice [Non-Movant]; trial remains set for [TRIAL_DATE] and other deadlines remain intact.

6. REQUESTED RELIEF

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

7. PROPOSED ORDER

text
IN THE IOWA DISTRICT COURT FOR [COUNTY_NAME] COUNTY
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, the Court finds good cause and ORDERS:

The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain as scheduled.

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

[JUDGE_NAME]
District Court Judge

8. SIGNATURE BLOCK

text
DATED: ______, [YEAR].

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

By: _____
[ATTORNEYNAME]
AT000[BAR_NUMBER]
Attorney for [MOVING_PARTY_NAME]

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] I electronically filed the foregoing with the Clerk of Court using EDMS, which will send notice to all registered counsel pursuant to Iowa R. Elec. P. 16.315. Copies were also served by [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.