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

(State of Minnesota, District Court, [JUDICIAL_DISTRICT] Judicial District)

1. CAPTION

text
STATE OF MINNESOTA ) DISTRICT COURT
COUNTY OF [COUNTY_NAME] ) [JUDICIAL_DISTRICT] JUDICIAL DISTRICT
) Court File No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. RULE 115.10 CERTIFICATION

Undersigned counsel certifies pursuant to Minn. Gen. R. Prac. 115.10 that [he/she/they] met and conferred with counsel for [Non-Movant] on [DATE]. [Non-Movant] [does not oppose / opposes / takes no position].

3. MOTION

[Movant] respectfully moves pursuant to Minn. R. Civ. P. 6.02 to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

4. FACTUAL BASIS

1. The Court’s [order/scheduling order] dated [ORDER_DATE] established the current deadline.
2. [Movant] has diligently [describe actions], including [FACT_DETAIL].
3. Additional time is needed because [REASONS], despite diligent efforts.
4. The requested extension will not affect the trial date of [TRIAL_DATE] or other case management deadlines.

5. LEGAL STANDARD

Rule 6.02 authorizes the Court to enlarge time for good cause when the request is made before expiration, and upon excusable neglect after expiration. Minnesota courts evaluate diligence, prejudice, and the interests of justice.

6. ARGUMENT

1. Good Cause/Excusable Neglect. [Detail facts supporting relief].
2. Diligence. [Describe steps taken to comply with the deadline].
3. Absence of Prejudice. Granting the extension will not prejudice [Non-Movant] and promotes resolution on the merits.

7. REQUESTED RELIEF

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

8. PROPOSED ORDER

text
STATE OF MINNESOTA ) DISTRICT COURT
COUNTY OF [COUNTY_NAME] ) [JUDICIAL_DISTRICT] JUDICIAL DISTRICT
) Court File No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

Upon consideration of [Movant]'s Motion for Extension of Time and good cause appearing, IT IS ORDERED that the motion is GRANTED. The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect.

Dated: ______, [YEAR]

BY THE COURT:

[JUDGE_NAME]
Judge of District Court

9. SIGNATURE BLOCK

text
Dated: ______, [YEAR].

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

By: _____
[ATTORNEYNAME]
Attorney Reg. No. [BAR_NUMBER]
Attorney for [MOVING_PARTY_NAME]

10. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed and served through the Minnesota eFile and eServe System in accordance with Minn. R. Civ. P. 5.02. Service by [method] was also made 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.