Fill and Sign the Motion Requesting Additional Time to Respond to Motion for Summary Judgment with Notice of Motion Form

IN THE UNITED STATES DISTRICT COURT FOR THE _______________________ (DISTRICT) OF ____________________________________________ (STATE) _________________________________ (DIVISION) ________________________________________ PLAINTIFF V. CIVIL ACTION NO. _____-_____ _________________________________________ DEFENDANT Motion for Extension of Time to Respond to Motion for Summary Judgment COMES NOW _________________________________, Defendant in the above- styled and numbered cause, by and through its attorneys, and respectfully moves, pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, for additional time to respond to the Motion for Summary Judgment filed in this action by Plaintiff, and would state in support thereof the following: 1. On or about _________________ (date), Plaintiff _________________________ , by and through his attorney, filed a Motion for Summary Judgment in this action.2. Additional discovery is needed to respond to the Motion (principally depositions of the affiants to Plaintiff’s Motion), which discovery is now being conducted on an expedited basis. 3. This Motion is filed not for purposes of delay but so that justice may be done. WHEREFORE, Defendant requests that the Court enter an Order allowing Defendant until ___________________ (date) to respond to the Motion for Summary Judgment filed in this action by Plaintiff. Respectfully Submitted, ____________________________________ ( Defendant) By_________________________________ (Name of Attorney) One of its Attorneys Certificate of Service This is to certify that I, ______________________________________ (Name of Attorney), attorney for Defendant ________________________________________, have this date served a true and correct copy of the above and foregoing Motion for Extension of Time to Respond to Motion for Summary Judgment by U.S. Mail, postage fully prepaid, to the following counsel of record for Plaintiff: ______________________________________________ (Name of Attorney) Post Office Box _________ _______________________________________________________________________ City, State, Zip Code This the ____day of ______________, 20___. Respectfully Submitted, ______________________________ (Name of Attorney) State Bar No. _____ Attorney for Defendant OF COUNSEL: __________________________________ (Name of Attorney) Post Office Box ______-_________ City, State, Zip Code_______________________________________________________ Telephone: _____-_____-__________ Notice of Motion for Extension of Time to Respond to Motion for Summary Judgment You are notified that on (date), at (time) , or as soon thereafter as counsel can be heard, in Courtroom 000 of the United States District Court for the (District) of (State), (Division) at the Federal Courthouse at (street address, city, county, state, zip code) , Defendant Acme, Inc., through its attorney, will move the court for an extension of time to respond to Plaintiff’s Motion for Summary Judgment for the reasons stated in the above Motion. ____________________________________(Defendant) By_________________________________ (Name of Attorney) Its Attorney Certificate of Service This is to certify that I, ________________________________________ (Name of Attorney), attorney for Defendant _________________________________________, have this date served a true and correct copy of the above and foregoing Notice of Motion for Extension of Time to Respond to Motion for Summary Judgment by U.S. Mail, postage fully prepaid, to the following counsel of record for Plaintiff: _________________________________________________ (Name of Attorney) Post Office Box _________ ________________________________________________________________________ City, State, Zip Code This the ____day of ____________, 20___. ______________________________ (Name of Attorney) State Bar No. _____ Attorney for Defendant OF COUNSEL: ________________________________________ (Name of Attorney) Post Office Box _____-_______ City, State, Zip Code_______________________________________________________ Telephone: _____-_____-_________