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 General Court of Justice, Superior Court Division, [COUNTY_NAME] County, North Carolina)

1. CAPTION

text
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
[COUNTY_NAME] COUNTY SUPERIOR COURT DIVISION
File No. [FILE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves under Rule 6(b) of the North Carolina Rules of Civil Procedure to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. FACTUAL BASIS

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

4. LEGAL STANDARD

Rule 6(b) authorizes the Court to enlarge deadlines for cause shown before the period expires, and upon a showing of excusable neglect after expiration. North Carolina courts weigh diligence, prejudice, and the interest of justice when assessing such motions.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain reasons supporting the extension].
2. Diligence. [Describe steps taken to comply].
3. Lack of Prejudice. Granting the extension will not prejudice [Non-Movant] and will maintain the 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 grant such other relief as the Court deems proper.

7. PROPOSED ORDER

text
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE
[COUNTY_NAME] COUNTY SUPERIOR COURT DIVISION
File No. [FILE_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 deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect.

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

[JUDGE_NAME]
Superior Court Judge Presiding

8. SIGNATURE BLOCK

text
Respectfully submitted this ___ day of ____, [YEAR].

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

By: _____
[ATTORNEYNAME]
N.C. State Bar No. [BAR_NUMBER]
Attorney for [MOVING_PARTY_NAME]

9. CERTIFICATE OF SERVICE

I hereby certify that on [SERVICE_DATE] the foregoing was served via [N.C. eCourts File & Serve / Email / U.S. Mail] pursuant to Rule 5 on the following:

[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.