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 [COUNTY_NAME] County, Kansas)

1. CAPTION

text
IN THE DISTRICT COURT OF [COUNTY_NAME] COUNTY, KANSAS
[CIVIL DEPARTMENT]

[PLAINTIFF_NAME],
Plaintiff,

v. Case No. [CASE_NUMBER]
Division [DIVISION]
[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves the Court pursuant to K.S.A. 60-206(b)(1) to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. FACTUAL BASIS

1. On [ORDER_DATE], the Court entered [identify order] establishing the current deadline.
2. [Movant] has diligently [describe actions], including [FACT_DETAIL].
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].
5. The requested extension will not affect the current trial date of [TRIAL_DATE] or other scheduled deadlines.

4. LEGAL STANDARD

K.S.A. 60-206(b) authorizes the Court to extend deadlines for good cause when sought before expiration, and for excusable neglect when sought afterward. Kansas Supreme Court Rule 133 requires motions to state with particularity the relief requested and supporting facts.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain specific circumstances necessitating extension].
2. Diligence. [Summarize efforts taken to meet the deadline].
3. Absence of Prejudice. The extension will not prejudice [Non-Movant]; it promotes adjudication on the merits and aligns with the scheduling order.

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 the Court deems just.

7. PROPOSED ORDER

text
IN THE DISTRICT COURT OF [COUNTY_NAME] COUNTY, KANSAS
Case No. [CASE_NUMBER]
Division [DIVISION]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

The Court, having reviewed [Movant]'s Motion for Extension of Time and finding good cause, ORDERS that the deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain as previously set.

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

[JUDGE_NAME]
District Judge

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

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

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed via the Kansas eFlex system, which sent notice to all counsel of record pursuant to K.S.A. 60-205. 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.