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

(Superior Court of Washington for [COUNTY_NAME] County)

1. CAPTION

text
SUPERIOR COURT OF WASHINGTON
FOR [COUNTY_NAME] COUNTY
No. [CASE_NUMBER]

[PLAINTIFF_NAME],
Plaintiff,

v.

[DEFENDANT_NAME],
Defendant.

2. MOTION

[Movant] respectfully moves pursuant to CR 6(b) for an extension of time to [describe act] from [CURRENT_DEADLINE] to [PROPOSED_NEW_DEADLINE].

3. CERTIFICATION OF CONFERENCE

Pursuant to CR 7 and LCR 7, 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 diligent efforts.
4. The requested extension will not impact the trial date of [TRIAL_DATE] or other scheduling order deadlines.

5. LEGAL STANDARD

CR 6(b) authorizes the Court to enlarge time for good cause before the expiration of the period, and upon excusable neglect when requested afterward. Washington courts consider diligence, prejudice, and the interests of justice.

6. ARGUMENT

1. Good Cause/Excusable Neglect. [Explain supporting circumstances].
2. Diligence. [Detail steps taken promptly].
3. Absence of Prejudice. Granting the extension will not prejudice [Non-Movant] and promotes a merits-based resolution.

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 the Court deems just.

8. PROPOSED ORDER

text
SUPERIOR COURT OF WASHINGTON
FOR [COUNTY_NAME] COUNTY
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 effect.

DATED this ___ day of ____, [YEAR].

[JUDGE_NAME]
Superior Court Judge

9. SIGNATURE BLOCK

text
DATED: ______, [YEAR].

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

By: _____
[ATTORNEYNAME]
WSBA No. [BAR_NUMBER]
Attorney for [MOVING_PARTY_NAME]

10. CERTIFICATE OF SERVICE

I certify that on [SERVICE_DATE] the foregoing was filed and served via Odyssey eFile & Serve pursuant to CR 5(b). 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.