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/SUPERIOR] Court of [COUNTY_NAME] County, Indiana)

1. CAPTION

text
STATE OF INDIANA )
) SS:
COUNTY OF [COUNTY_NAME] )

IN THE [CIRCUIT/SUPERIOR] COURT OF [COUNTY_NAME] COUNTY
CAUSE NO. [CAUSE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves the Court pursuant to Indiana Trial Rule 6(B) to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. GROUNDS

1. The Court’s [order/scheduling order] dated [ORDER_DATE] set the current deadline.
2. [Movant] has diligently [describe efforts], including [FACT_DETAIL].
3. Additional time is needed 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

Trial Rule 6(B) permits enlargement of time for good cause when the request is made before expiration, and for excusable neglect when made thereafter. Indiana courts favor resolving cases on the merits when no party is prejudiced.

5. ARGUMENT

1. Good Cause. [Explain basis for relief].
2. Diligence. [Describe steps already taken to comply].
3. Absence of Prejudice. The requested extension will not prejudice [Non-Movant]; existing dates, including trial on [TRIAL_DATE], remain intact.

6. REQUESTED RELIEF

WHEREFORE, [Movant] prays that the Court extend the deadline for [describe act] to [PROPOSED_NEW_DEADLINE] and for all other just and proper relief.

7. PROPOSED ORDER

text
IN THE [CIRCUIT/SUPERIOR] COURT OF [COUNTY_NAME] COUNTY
STATE OF INDIANA
CAUSE NO. [CAUSE_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 being duly advised, now finds that the motion should be GRANTED.

IT IS THEREFORE ORDERED that the deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect.

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

[JUDGE_NAME]
Judge, [CIRCUIT/SUPERIOR] Court

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

By: ______
[ATTORNEY_NAME]
Attorney No. [BAR_NUMBER]
Counsel for [MOVING_PARTY_NAME]
Date: ____, [YEAR]

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed electronically through the Indiana E-Filing System and served on all counsel of record pursuant to Ind. Trial Rule 5(b). Service was also made 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.