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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}.

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