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UNITED STATES DISTRICT COURT

[courtDistrict], [courtDivision]

[plfName]	)	Case No (LT)
Plaintiff	)	[caseNo]
)
v.	)
)
[defName]	)
Defendant	)

PLAINTIFF’S MOTION FOR AN EXTENSION OF TIME (TO COMPLETE THE JOINT CASE MANAGEMENT REPORT)

Plaintiff, [plfName], on this [D] day of [MMMM] [YYYY], respectfully asks this Court to grant the parties an additional ten ([NN]) days to complete the case management report.

Key Points:

Grounds	good cause; [addlRzn]

Table of Contents:

Context	2nd Page
Motion	3rd Page
Certificates	9th Page

Background:	Plaintiff recently learned of a deadline
Problem:	Plaintiff will not be able to meet the deadline
Request:	This Court extends the deadline (by [NN] days)

Rule 1 Fed. R. Civ. P. | Scope

“[These rules] should be... administered... by the court... to secure the just, speedy, and inexpensive determination of every action...”

Rule 6(b)(1) Fed. R. Civ. P. | Scope

“In general. When an act may or must be done within a specified time, the court may, for good cause, extend the time…”

Precedence

6:23-cv-01945-ACC-LHP	- USFLMD (11/28/23)

8:22-cv-02548-CEH-JSS	- USFLMD (6/21/23)

2:20-cv-00814-SPC-NPM	- USFLMD (1/14/22)

6:18-cv-00437-GAP-LRH	- USFLMD (6/7/19)

2:18-cv-00061-JES-UAM	- USFLMD (3/4/19)

2:18-cv-00438-SPC-UAM	- USFLMD (1/30/19)

2:18-cv-00274-PAM-NPM	- USFLMD (11/27/18)

8:18-cv-00738-SCB-TGW	- USFLMD (5/19/18)

This Court has regularly granted nearly-identical motions

Abbreviations:

USFLMD	-	US District Court, Florida, Middle District

MOTION

Relevant History

[hstry001]

[hstry002]

[hstry003]

Analysis

[any001]

[any002]

[any003]

Standard for Review

Rule 6(b) Fed. R. Civ. P. governs Motions for Extensions of Time:

“(1) In General. When an act may or must be done within a specified time, the court may, for good cause, extend the time:

(A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires;”

Rule 6(b)(1)(A) Fed. R. Civ. P.

According to the 11th Circuit Court of Appeals, this Court has broad discretion in deploying Rule 6 (highlights added):

“We recognize that district courts enjoy broad discretion in deciding how best to manage the cases before them. See, e.g., United States v. McCutcheon, 86 F.3d 187 (11th Cir. 1996). This discretion is not unfettered, however. When a litigant’s rights are materially prejudiced by the district court’s mismanagement of a case, we must redress the abuse of discretion.”

Chudasama v. Mazda, 123 F.3d 1353 (11th Cir. 1997)

This Court employs that 11th Circuit holding in the following way (highlights added):

“In exercising this discretion, a court may extend the time concerning when an act must be done within a specific time if the request is made before the original time, or its extension expires... Here, Defendant’s Motion was timely filed, and the court finds good cause to extend the deadlines as requested.”

Turner v. Progressive, 8:22-cv-02548 (6/21/23 USFLMD)

In short, this Court grants these types of motions if:

the motion was filed before the deadline; and/or

the movant showed good cause.

In the instant case, Plaintiff has satisfied both prongs.

Application

[app01]

[app02]

[app03]

As a bonus, Plaintiff hereby states that the non-movant (ie, Defendants) will not be prejudiced by this extension. For one, Defendant has never expressed/indicated harm. And, secondly, Plaintiff sees no harm in the relief he seeks.

Nature of Relief Sought

Plaintiff seeks a [NN] day extension of this Court’s deadline (for the Case Management Report); as follows:

Current Deadline:	[dueDtBfr]
New Deadline:	[dueDtAftr]

CONFERRAL

On [confMth] [confDy], [confYr], [conferralStatement].

CONCLUSION

WHEREFORE, Plaintiff respectfully asks this Court to enter an Order Extending the Deadline (for the Parties to Complete the Case Management Report). Specifically, Plaintiff seeks a 10-day extension (up-to-and-including [MTH] [DY], [YR]).

Dated this [DD]th day of [MMMM] [YYYY].

Respectfully submitted,

/s/ [plfName]

[plfName], Plaintiff

[plfAddy]

P: [plfPhn]

E: [plfEml]

W: TextBookDiscrimination.com

Get Booked Up on Justice!

CERTIFICATE OF COMPLIANCE

I certify that the size and style of type used in this document is Times New Roman 14-point Font (caption) and Century Schoolbook 13-point Font (contents); thus complying with the font requirements of Local Rule 1.08.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this [D] day of [MMM] [YYYY], I electronically filed the foregoing with the Clerk of Courts by using its online filing page. I also emailed it to the attached service list.

/s/ [plfName]

Endnotes:

How-To Guide: (interactive)

TextBookDiscrimination.com/Guides/Motions/Extension

SERVICE LIST

[defAtt], Esquire ([barNum]) E: [defEml] P: [defPhn] (defendant’s trial lawyers)

EXHIBIT 101

EXHIBIT 102

PLAINTIFF’S AFFIDAVIT

UNITED STATES DISTRICT COURT

[courtDistrict], [courtDivision]

[plfName]	)	Case No (LT)
Plaintiff	)	[caseNo]
)
v.	)
)
[defName]	)
Defendant	)

PLAINTIFF’S AFFIDAVIT IN SUPPORT OF ‘PLAINTIFF’S MOTION FOR AN EXTENSION OF TIME (TO COMPLETE THE JOINT CASE MANAGEMENT REPORT)’

The affiant, [plfName], swears or affirms as follows:

Background

I am over the age of eighteen (18).

I am a plaintiff in the above-captioned case.

This affidavit is made in good faith.

Familiarity

I have read the Local Rules of Court, the Federal Rules of Civil Procedure, the Federal Rules of Evidence, and much more.

The information in this affidavit is based on my own personal knowledge.

Facts

[fact001]

[fact002]

[fact003]

[fact004]

[fact005]

[fact006]

Request

[req001]

Thank you.

Verification Under Oath Pursuant to 28 USC §1746

I declare under penalty of perjury that the foregoing is true and correct. Executed on this [DD]th day of [MMMM] [YYYY].

UNITED STATES OF AMERICA	[dtSigned]
[plfName], Plaintiff/Affiant

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