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 District Court of the [JUDICIAL_DISTRICT] Judicial District of the State of Idaho, in and for the County of [COUNTY_NAME])

1. CAPTION

text
IN THE DISTRICT COURT OF THE [JUDICIAL_DISTRICT] JUDICIAL DISTRICT
OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF [COUNTY_NAME]

[PLAINTIFF_NAME],
Plaintiff,

v. Case No. [CASE_NUMBER]

[DEFENDANT_NAME],
Defendant.

2. MOTION

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

3. GROUNDS

1. The Court’s [order/scheduling notice] dated [ORDER_DATE] established the current deadline.
2. [Movant] has diligently [describe actions], including [FACT_DETAILS].
3. Additional time is required because [REASONS], despite reasonable diligence.
4. Counsel conferred with [Opposing Counsel] on [DATE]; [Opposing Party] [consents / does not oppose / objects].

4. LEGAL STANDARD

I.R.C.P. 6(b) permits the Court to extend time for good cause when the request is made before expiration, and on a showing of excusable neglect if made afterward. Courts consider diligence, prejudice, and impact on existing schedules.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain circumstances necessitating extension].
2. Diligence. [Detail efforts to comply with the original deadline].
3. No Prejudice. The requested extension will not prejudice [Non-Movant]; trial remains set for [TRIAL_DATE] and other deadlines remain feasible.

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 the Court deems just.

7. PROPOSED ORDER

text
IN THE DISTRICT COURT OF THE [JUDICIAL_DISTRICT] JUDICIAL DISTRICT
OF THE STATE OF IDAHO, IN AND FOR THE COUNTY OF [COUNTY_NAME]
Case No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

Good cause appearing, IT IS HEREBY ORDERED that the deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other provisions of the scheduling order remain in effect.

DATED this ___ day of ____, [YEAR].

[JUDGE_NAME]
District Judge

8. SIGNATURE BLOCK

text
DATED this ___ day of ____, [YEAR].

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

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

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] I filed the foregoing via the iCourt electronic filing system, which served all registered counsel pursuant to I.R.C.P. 5(b). 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.