How-To: Drafting/Filing Your Response to a Motion for Extension of Time

II. Samples

#	PDF	Comments
1		TBD case. USFLMD. Pro Se Filing. 2020 | Responsive Pleading Deadline
2		DOAH Case | 2010 | Attorney Filing | Reconsideration+
3		DOAH Case | 2011 | Attorney Filing | Order of Dismissal
4		DOAH Case | 2012 | Attorney Filing | COVID-19 Trouble | Discovery Deadline | Due Process
5		DOAH Case | 2013 | Attorney Filing | Exhibits into Evidence
6		DOAH Case | 2017 | Attorney Filing | Response to Summary Judgment
7		DOAH Case | 2020 | Attorney Filing | COVID-19 Trouble | Discovery Deadline

III. Templates

#	Word	Comments
1		Replace all of the placeholder tags with real information (eg "[plfName]" becomes "John Doe").

IV. Quick Commentary

• Note: Courts have an obligation to manage their dockets efficiently
  "The Court “must take an active role in managing cases on [its] docket” and enjoys broad discretion “in deciding how best to manage the cases before [it].” "
  - see Chudasama v. Mazda, 123 F.3d 1353, 1366 (11th Cir. 1997)
  
  
• Standard of Review: 3 Factors “Factors to be considered in determining whether the trial court abused its discretion in denying the motion for continuance include whether the denial of the continuance creates an injustice for the movant; whether the cause of the request for continuance was unforeseeable by the movant and not the result of dilatory practices; and whether the opposing party would suffer any prejudice or inconvenience as a result of a continuance.” - see Fleming v Fleming, 710 So. 2d 601 (Fla. 4th DCA 1998)
  
  
  1. Injustice to Movant (upon Denial)
     
     • ie, will the movant be at a disadvantage if an extension is not granted?
  2. Unforeseeable need for continuance; and
     
     • ie, could the request have been avoided?
  3. Prejudice to Non-Movant
     
     • will an extension irreparably harm to the party who opposes it?
• Download as many sample documents as you'd like
  • Model your language after the language that lawyers use
• Use the free-hand template (see Part III - above) to write your 'Response'
• Save the final version as a PDF file.
• File the final version in court

V. Additional Notes

• Estimated Time ≈ 1-10 hours

VI. Bibliography

• Chudasama v. Mazda, 123 F.3d 1353, 1366 (11th Cir. 1997)
• Fleming v Fleming, 710 So. 2d 601 (Fla. 4th DCA 1998)

VII. Conclusion

With the use of the template (as well as the samples above), you can more easily draft your Response in Opposition to Defendant's Motion for an Extension of Time.