State Court Motion for Extension of Time

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 in and for [COUNTY_NAME] County, State of Oklahoma)

1. CAPTION

IN THE DISTRICT COURT IN AND FOR
[COUNTY_NAME] COUNTY STATE OF OKLAHOMA
Case No. [CASE_NUMBER]

[PLAINTIFF_NAME],
    Plaintiff,

v.

[DEFENDANT_NAME],
    Defendant.

2. MOTION

[Movant] respectfully moves pursuant to 12 O.S. § 2006(B) for an extension of time to [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. FACTUAL BASIS

1. The Court’s [order/scheduling order] dated [ORDER_DATE] established the deadline at issue.
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

Section 2006(B) authorizes the Court to enlarge time for cause shown and upon excusable neglect when sought after the deadline. Oklahoma courts consider diligence, prejudice, and good faith.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain supporting circumstances].
2. Diligence. [Detail steps taken promptly].
3. No Prejudice. Granting the extension will not prejudice [Non-Movant] and will not delay 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 is just and proper.

7. PROPOSED ORDER

IN THE DISTRICT COURT IN AND FOR
[COUNTY_NAME] COUNTY STATE OF OKLAHOMA
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 for good cause shown, IT IS ORDERED that the deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect.

DATED this ___ day of __________, [YEAR].

__________________________________
[JUDGE_NAME]
District Judge

8. SIGNATURE BLOCK

Respectfully submitted,

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

By: __________________________________
    [ATTORNEY_NAME]
    OBA No. [BAR_NUMBER]
    Attorney for [MOVING_PARTY_NAME]
Date: ____________, [YEAR]

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was [e-filed / served] via [Oklahoma e-filing / Email / U.S. Mail] pursuant to 12 O.S. § 2005(B) 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.