Fill and Sign the Motion for Additional Time to Respond to Motion for Summary Judgment and to Reset Hearing Mississippi Form

IN THE COUNTY COURT OF       COUNTY, MISSISSIPPI       PLAINTIFF(S) VS. CIVIL ACTION NO.             DEFENDANT(S) MOTION FOR ADDITIONAL TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT AND TO RESET HEARING COMES Defendant,       , Individually and       by and through counsel and files this his/her Motion For additional Time to respond to Motion for Summary Judgment and to Reset Hearing and would state in support thereof the following: 1. Plaintiffs filed a Motion for Summary Judgment, Itemization of Facts, Affidavit in Support of Motion for Summary Judgment, Memorandum and Notice of Hearing on       , which Defendant received on       . 2. Due to the heavy court schedule of Defendant's attorney and previously scheduled meetings and hearings, there is not sufficient time in which to prepare and file an adequate response on Defendant's behalf. 3. Plaintiffs' counsel arbitrarily set a hearing of the matter for       at       a.m./p.m. without benefit of discussion with counsel for Defendant. Defendant has attempted in good faith to resolve the scheduling conflict with counsel for Plaintiffs but Plaintiffs' counsel has advised that his/her clients will not agree to resetting the hearing on the Motion. See copy of letter attached hereto as Exhibit "       ". 4. Plaintiff(s) will suffer no prejudice if Defendant is granted an extension of time to respond to Plaintiffs' Motion for Summary Judgment and resetting of the Hearing. This request is not an attempt at delay but rather to insure that Defendant will suffer no prejudice by allowing Defendant the opportunity to adequately and fully respond to said Motion. WHEREFORE, PREMISES CONSIDERED, Defendant,       , Individually and       moves this Court for an additional       (       ) days in which to respond to Plaintiffs' Motion for Summary Judgment and that a hearing on the Motion will be reset to a date that is agreeable to this Court and all parties. Respectfully submitted, ___________________________       , ATTORNEY FOR       , INDIVIDUALLY AND       CERTIFICATE OF SERVICE I,       do hereby certify that I have mailed this day by U.S. Mail, postage prepaid, a true and correct copy of the above and foregoing Motion to       Dated this the       day of       , 20       . ___________________________