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, Missouri)

1. CAPTION

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, MISSOURI
[DIVISION]
Case No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves, pursuant to Missouri Supreme Court Rule 44.01(b), to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. 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 necessary because [REASONS], despite due diligence.
4. Counsel conferred with [Opposing Counsel] on [DATE]; [Opposing Party] [consents / does not oppose / objects].

4. LEGAL STANDARD

Rule 44.01(b) authorizes the Court to extend time for good cause when the request is made before expiration, and for excusable neglect when made thereafter. Missouri courts evaluate diligence, prejudice, and the interests of justice in determining good cause.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain circumstances warranting relief].
2. Diligence. [Detail steps taken to comply with existing deadline].
3. No Prejudice. Granting the extension will not prejudice [Non-Movant] and maintains the existing trial date of [TRIAL_DATE].

6. REQUESTED RELIEF

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

7. PROPOSED ORDER

text
IN THE CIRCUIT COURT OF [COUNTY_NAME] COUNTY, MISSOURI
Case 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 as previously set.

Dated: ______, [YEAR]

[JUDGE_NAME]
Circuit Judge

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

By: ______
[ATTORNEY_NAME]
Missouri Bar 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 Missouri eFiling system, which sent notice to all registered counsel pursuant to Rule 43.01. 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.