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

(Superior Court of New Jersey, Law Division, Civil Part)

1. CAPTION

text
SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: [COUNTY_NAME] COUNTY
DOCKET NO.: [DOCKET_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. NOTICE OF MOTION

PLEASE TAKE NOTICE that on [HEARING_DATE] at [HEARING_TIME], or as soon thereafter as counsel may be heard, [Movant] will move before the Honorable [JUDGE_NAME], J.S.C., for an order extending the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE], pursuant to R. 1:3-4(c).

3. CERTIFICATION

In support of this motion, [Movant] submits the annexed Certification of [CERTIFIER_NAME] pursuant to R. 1:6-6.

4. GROUNDS FOR RELIEF

1. The Court’s [order/case management 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].

5. LEGAL STANDARD

R. 1:3-4(c) authorizes the Court to enlarge time for good cause. When the period has expired, relief requires a showing of excusable neglect. Courts consider diligence, prejudice, and the administration of justice.

6. ARGUMENT

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

7. RELIEF REQUESTED

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

8. PROPOSED FORM OF ORDER

text
SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: [COUNTY_NAME] COUNTY
DOCKET NO.: [DOCKET_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

The Motion of [Movant] for an extension of time having been considered, and for good cause shown, IT IS on this ___ day of ____, [YEAR],

ORDERED that the deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]; and it is further

ORDERED that all other provisions of prior orders remain in effect.

Hon. [JUDGE_NAME], J.S.C.

9. SIGNATURE BLOCK

text
Dated: ______, [YEAR]

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

By: _____
[ATTORNEYNAME]
NJ Attorney ID [BAR_NUMBER]
Attorney for [MOVING_PARTY_NAME]

10. CERTIFICATE OF SERVICE

I hereby certify that on [SERVICE_DATE] a true copy of the foregoing was filed via eCourts and served upon all counsel of record pursuant to R. 1:5-2. Service by [method] was also made on:

[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.