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 [EIGHTH] Judicial District Court of the State of Nevada, in and for the County of [COUNTY_NAME])

1. CAPTION

text
DISTRICT COURT
CLARK COUNTY, NEVADA
Case No. [CASE_NUMBER]
Dept. No. [DEPARTMENT]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves pursuant to NRCP 6(b) and EDCR 2.20 for an extension of time to [describe act], extending the current deadline of [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. MEET-AND-CONFER STATEMENT

Pursuant to EDCR 2.34, undersigned counsel certifies that [he/she/they] conferred with [Opposing Counsel] on [DATE]; [Opposing Party] [does not oppose / opposes / takes no position].

4. FACTUAL BASIS

1. On [ORDER_DATE], the Court entered [order] establishing the current deadline.
2. [Movant] has diligently [describe actions], including [FACT_DETAIL].
3. Despite diligence, additional time is needed because [REASONS].
4. The requested extension will not impact the current trial date of [TRIAL_DATE] or other scheduled deadlines.

5. LEGAL STANDARD

NRCP 6(b) authorizes enlargement of time for good cause when the request is made before expiration and for excusable neglect when made thereafter. EDCR 2.20 requires motions to be supported by points and authorities demonstrating diligence and lack of prejudice.

6. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain supporting circumstances].
2. Diligence. [Detail steps taken to comply with existing deadlines].
3. Absence of Prejudice. Granting the extension will not prejudice [Non-Movant]; it promotes adjudication 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 may be just.

8. PROPOSED ORDER

text
DISTRICT COURT
CLARK COUNTY, NEVADA
Case No. [CASE_NUMBER]
Dept. No. [DEPARTMENT]

[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 good cause appearing, ORDERS that the motion is GRANTED. The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect.

DATED: ______, [YEAR]

[JUDGE_NAME]
District Judge

9. SIGNATURE BLOCK

text
DATED: ______, [YEAR].

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

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

10. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] I electronically filed the foregoing with the Clerk of the Court using the Odyssey File & Serve system, which served all registered parties pursuant to NRCP 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.