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, State of North Dakota)

1. CAPTION

text
STATE OF NORTH DAKOTA ) IN DISTRICT COURT
COUNTY OF [COUNTY_NAME] ) [JUDICIAL_DISTRICT] JUDICIAL DISTRICT
) Case No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves pursuant to N.D.R.Civ.P. 6(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 required because [REASONS], despite reasonable 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 time for good cause when the request is made before expiration and upon excusable neglect when made thereafter. Courts consider diligence, prejudice, and the interests of justice.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Detail supporting circumstances].
2. Diligence. [Describe steps taken promptly].
3. No Prejudice. Granting the extension will not prejudice [Non-Movant]; trial remains scheduled for [TRIAL_DATE].

6. REQUESTED RELIEF

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

7. PROPOSED ORDER

text
STATE OF NORTH DAKOTA ) IN DISTRICT COURT
COUNTY OF [COUNTY_NAME] ) [JUDICIAL_DISTRICT] JUDICIAL DISTRICT
) Case No. [CASE_NUMBER]

[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 unchanged.

Dated this ___ day of ____, [YEAR].

BY THE COURT:

[JUDGE_NAME]
District Judge

8. SIGNATURE BLOCK

text
Dated: ______, [YEAR].

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

By: _____
[ATTORNEYNAME]
ND Bar ID [BAR_NUMBER]
Attorney for [MOVING_PARTY_NAME]

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed via Odyssey eFileND and served on all registered counsel pursuant to N.D.R.Civ.P. 5(b). 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.