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 [JUDICIAL_CIRCUIT] Judicial Circuit Court, [COUNTY_NAME] County, Kentucky)

1. CAPTION

text
COMMONWEALTH OF KENTUCKY
[COUNTY_NAME] CIRCUIT COURT
CIVIL ACTION NO. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves the Court pursuant to CR 6.02 to enlarge the time within which [describe act] must be completed, extending the current deadline of [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. STATEMENT OF GROUNDS

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

4. LEGAL STANDARD

CR 6.02 authorizes the Court to enlarge deadlines for cause shown when the motion is made before the period expires and, if after expiration, upon a showing of excusable neglect. Kentucky courts consider diligence, prejudice, and whether the extension will disturb the trial schedule.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Describe circumstances necessitating extension].
2. Diligence. [Summarize actions taken to meet the deadline].
3. Absence of Prejudice. The requested extension will not prejudice [Non-Movant]; the trial date of [TRIAL_DATE] remains unaffected.

6. REQUEST FOR RELIEF

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

7. PROPOSED ORDER

text
COMMONWEALTH OF KENTUCKY
[COUNTY_NAME] CIRCUIT COURT
CIVIL ACTION NO. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

Upon the motion of [Movant] and the Court being otherwise sufficiently advised, IT IS HEREBY 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, [JUDICIAL_CIRCUIT] Judicial Circuit

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

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

9. CERTIFICATE OF SERVICE

I hereby certify that on [SERVICE_DATE] I filed the foregoing via Kentucky Court of Justice eFiling, which served all registered counsel pursuant to CR 5.02. 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.