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 [COUNTY_NAME] County, Illinois [District/Division])

1. CAPTION

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, ILLINOIS
[LAW DIVISION / CHANCERY / MUNICIPAL]

[PLAINTIFF_NAME],
Plaintiff,

v. No. [CASE_NUMBER]
Calendar [CALENDAR]
[DEFENDANT_NAME], Judge [JUDGE_NAME]
Defendant.

2. MOTION

[Movant], through undersigned counsel, moves pursuant to 735 ILCS 5/2-1007 and Supreme Court Rule 183 for an extension of time to [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. FACTUAL BASIS

1. On [ORDER_DATE], the Court entered [describe order] establishing the current deadline.
2. [Movant] has diligently [describe efforts], including [FACT_DETAIL].
3. Additional time is required because [REASONS], despite the exercise of due diligence.
4. Counsel conferred with [Opposing Counsel] on [DATE]; [Opposing Party] [consents / does not oppose / objects].
5. This request is made in good faith and not to cause undue delay.

4. LEGAL STANDARD

Section 2-1007 authorizes the Court to extend any deadline on just terms, and Supreme Court Rule 183 allows enlargement upon a showing of good cause. When filed after expiration, a showing of reasonable excuse or excusable neglect is required.

5. ARGUMENT

1. Good Cause Exists. [Explain reasons necessitating extension].
2. Diligence Demonstrated. [Detail steps taken promptly to comply].
3. No Prejudice. The requested extension will not prejudice [Non-Movant]; trial remains set for [TRIAL_DATE] and existing deadlines remain manageable.

6. REQUESTED RELIEF

WHEREFORE, [Movant] respectfully requests that the Court extend the deadline for [describe act] to [PROPOSED_NEW_DEADLINE], adjust any related dates as needed, and award such further relief as deemed appropriate.

7. PROPOSED ORDER

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, ILLINOIS
No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

This matter coming to be heard on [Movant]'s Motion for Extension of Time, due notice having been given, and the Court being fully advised, IT IS HEREBY ORDERED:

The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other dates remain in effect unless otherwise ordered.

Dated: ______, [YEAR]

ENTER:

Judge [JUDGE_NAME]

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

By: ______
[ATTORNEY_NAME]
ARDC No. [ARDC_NUMBER]
Attorney for [MOVING_PARTY_NAME]
Date: ____, [YEAR]

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] I electronically filed the foregoing with the Clerk of the Circuit Court using Odyssey eFileIL, which sent notification of such filing to all registered counsel pursuant to Supreme Court Rule 11. I also served via [method] the following:

[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.