Motion to Extend Time

{STYLE OF THE CASE}

{PARTY}’S MOTION TO EXTEND TIME

{Party} asks the court to extend the time to {describe required act}, as allowed by __ Rule of Civil Procedure __.

A.  Introduction

1. Plaintiff is {name}; defendant is {name}.
2. Plaintiff sued defendant for {state basis of suit}.
3. Discovery in this suit is governed by a Level {1/2/3} discovery-control plan.  The discovery period {will end/ended} on {date}.
4. This case is set for {trial/hearing} on {date}.

    

                                                 B.  Facts

    

5. {Describe the circumstances that triggered the act the party must perform.}
6. {Party} {must/was required to} {describe required act} by {date}.
7. {State other facts relevant to the motion.}
8. {Party} attaches affidavits to this motion as Exhibits {letters} to establish facts not apparent from the record and incorporates them by reference.

    

                                              C.  Argument & Authorities

    

9. {Party} asks the court to extend the deadline until {date}.
   {CHOOSE APPROPRIATE PARAGRAPH 10}
   {To request additional time before deadline}
10. {Party} asks the court to grant additional time to {describe required act} because {party} can establish facts that support "cause shown" for an extension of time.  {State facts that support "cause shown," e.g., the area of law for the memorandum is complex and requires additional research that cannot be completed before the deadline.}
    {To request additional time after deadline}
11. {Party} asks the court to grant additional time to {describe required act} because {party} can show good cause for an extension of time.  {State specific facts that show good cause, e.g., attorney was in a car wreck and was unable to finish the response in time to file it by the deadline.}
12. {Party} requests additional time for the reasons stated in this motion, and not to delay these proceedings.  See

     

                                                     D.  Conclusion

     

13. {Briefly summarize the motion.}

     

                                                     E.  Prayer

     

14. For these reasons, {party} asks the court to set this motion for hearing and, after the hearing, grant {his/her/its} motion to extend the time to {describe required act} and extend the deadline until {date}.