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

(Court of Common Pleas of [COUNTY_NAME] County, Pennsylvania)

1. CAPTION

text
IN THE COURT OF COMMON PLEAS OF [COUNTY_NAME] COUNTY, PENNSYLVANIA
[CIVIL TRIAL / COMMERCE] DIVISION
No. [DOCKET_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant], by and through undersigned counsel, moves pursuant to Pa.R.C.P. 106 for an extension of time to [describe act], extending the current deadline of [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. FACTUAL BASIS

1. The Court’s [order/scheduling order] entered on [ORDER_DATE] set 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

Pa.R.C.P. 106 authorizes courts to enlarge time periods for good cause. When the period has expired, relief requires a showing of reasonable excuse or excusable neglect. Courts consider diligence, prejudice, and the administration of justice.

5. ARGUMENT

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

6. REQUESTED RELIEF

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.

7. PROPOSED ORDER

text
IN THE COURT OF COMMON PLEAS OF [COUNTY_NAME] COUNTY, PENNSYLVANIA
No. [DOCKET_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

AND NOW, this ___ day of ____, [YEAR], upon consideration of [Movant]'s Motion for Extension of Time, it is hereby ORDERED that the motion is GRANTED. The deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect.

BY THE COURT:

[JUDGE_NAME], J.

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

By: ______
[ATTORNEY_NAME]
Attorney I.D. No. [BAR_NUMBER]
Counsel for [MOVING_PARTY_NAME]
Date: ____, [YEAR]

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed via PACFile and served on all counsel of record pursuant to Pa.R.C.P. 205.4(g) and 440. 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.