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 Circuit Court of the State of Oregon for the County of [COUNTY_NAME])

1. CAPTION

text
IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR THE COUNTY OF [COUNTY_NAME]
Case No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves pursuant to ORCP 15 D to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. CERTIFICATION OF CONFERRAL

Pursuant to UTCR 5.010, undersigned counsel certifies that [he/she/they] conferred with counsel for [Opposing Party] 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. Additional time is required because [REASONS], despite due diligence.
4. The requested extension will not impact the trial date of [TRIAL_DATE] or other scheduled events.

5. LEGAL STANDARD

ORCP 15 D permits the Court to enlarge any time period for good cause, including after expiration upon a showing of excusable neglect. Courts consider diligence, prejudice, and the interests of justice.

6. ARGUMENT

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

8. PROPOSED ORDER

text
IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR THE COUNTY OF [COUNTY_NAME]
Case No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

The Court, having considered [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 in full force and effect.

DATED this ___ day of ____, [YEAR].

[JUDGE_NAME]
Circuit Court Judge

9. SIGNATURE BLOCK

text
DATED: ______, [YEAR].

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

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

10. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed via the Oregon Judicial Department eFile system and served on all registered users pursuant to ORCP 9. 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.