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/CHANCERY] Court for [COUNTY_NAME] County, Tennessee)

1. CAPTION

text
IN THE [CIRCUIT/CHANCERY] COURT FOR [COUNTY_NAME] COUNTY, TENNESSEE
Docket No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves pursuant to Tenn. R. Civ. P. 6.02 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] dated [ORDER_DATE] established the deadline.
2. [Movant] has diligently [describe actions], including [FACT_DETAIL].
3. Additional time is needed because [REASONS], despite reasonable diligence.
4. Counsel conferred with [Opposing Counsel] on [DATE]; [Opposing Party] [consents / does not oppose / objects].

4. LEGAL STANDARD

Rule 6.02 authorizes the Court to enlarge time for cause shown when the motion is made before expiration and upon excusable neglect after expiration. Tennessee courts consider diligence, prejudice, and whether the delay was reasonable.

5. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain supporting circumstances].
2. Diligence. [Detail steps taken promptly].
3. No Prejudice. The requested extension will not prejudice [Non-Movant] and will not affect the current trial setting 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 further relief as is just.

7. PROPOSED ORDER

text
IN THE [CIRCUIT/CHANCERY] COURT FOR [COUNTY_NAME] COUNTY, TENNESSEE
Docket 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 good cause appearing, IT IS ORDERED that the deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain as scheduled.

ENTER this ___ day of ____, [YEAR].

[JUDGE_NAME]

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

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

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed via the Tennessee e-filing system (or served by [method]) pursuant to Tenn. R. Civ. P. 5.02 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.