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 [___] Judicial District Court of [COUNTY_NAME] County, Texas)

1. CAPTION

text
CAUSE NO. [CAUSE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v. IN THE [___] JUDICIAL DISTRICT COURT
[COUNTY_NAME] COUNTY, TEXAS
[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves pursuant to Texas Rules of Civil Procedure 5 and 166 to extend the deadline for [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. FACTUAL BASIS

1. The Court’s [order/scheduling order] signed on [ORDER_DATE] established the current deadline.
2. [Movant] has diligently [describe actions], including [FACT_DETAIL].
3. Additional time is required because [REASONS], despite diligent efforts.
4. Counsel conferred with [Opposing Counsel] on [DATE] in compliance with Tex. R. Civ. P. 191.2; [Opposing Party] [does not oppose / opposes / takes no position].

4. LEGAL STANDARD

Rule 5 permits extension for good cause, including after expiration upon a showing of good cause/excusable neglect. Rule 166 empowers the Court to control its docket and modify deadlines for good cause. Texas courts evaluate diligence, prejudice, and impact on trial settings.

5. ARGUMENT

1. Good Cause Exists. [Explain circumstances necessitating extension].
2. Diligence. [Detail efforts taken to comply].
3. No Prejudice. The requested extension will not prejudice [Non-Movant] and will not affect the trial date of [TRIAL_DATE].

6. REQUESTED RELIEF

WHEREFORE, [Movant] prays that the Court extend the deadline for [describe act] to [PROPOSED_NEW_DEADLINE] and grant such other relief to which [Movant] may be justly entitled.

7. PROPOSED ORDER

text
CAUSE NO. [CAUSE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v. IN THE [___] JUDICIAL DISTRICT COURT
[COUNTY_NAME] COUNTY, TEXAS
[DEFENDANT_NAME],
Defendant.

ORDER GRANTING MOTION FOR EXTENSION OF TIME

On this day the Court considered [Movant]'s Motion for Extension of Time. After considering the motion and arguments of counsel, the Court finds that good cause exists. IT IS THEREFORE ORDERED that the deadline for [describe act] is extended to [PROPOSED_NEW_DEADLINE]. All other deadlines remain in effect.

SIGNED on ______, [YEAR].

JUDGE PRESIDING

8. SIGNATURE BLOCK

text
Respectfully submitted,

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

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

9. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing Motion for Extension of Time was served via eFileTexas in accordance with Tex. R. Civ. P. 21a, and by [method] 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.