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Whats the proper verbiage to use in my Motion for Extension of Time because I contracted Covid and my deadline is approaching?

likehelpful
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As an opposing attorney, reach out to opposing counsel and LET THEM KNOW before you file the motion to give them a heads up. I just got one with no notice and I was pissed at the bs excuses opposing counsel cited in their motion. If you have covid, just tell me and then file the brief so I can file a letter to the court supporting an extension.

likesmart

Don’t you see a formal submission on electronic court files?

You should talk to OC and get them to agree to an extension. Then file the extension as a Stipulation between the parties? Situations like these are exactly why ppl should be civil with each other regardless of their argument. You never know when youll find yourself needing OC to be the one helping you out.

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I would use the C word rather than a vague reference to illness.

likesmart

This is credited. My judge is sympathetic, but skeptical, to general “illness” reasons. But the moment you use the “c word” s/he will grant any extension almost automatically. But also, as people have pointed out elsewhere, just request a stip. from OC. Judges don’t like ex parte applications for continuances/extensions, even if they’re unopposed, for things that should just be a stip.

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If I was the opposing lawyer I’d agree to jointly submit that motion or represent that I don’t oppose it, etc. you should throw that in there perhaps and get their consent before you file. Unless the judge is an evil sociopath it will probably get granted

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Ask OC for a stipulated extension first. If/when they don’t agree, you can bring your motion and make them look like an asshat at the same time. Say you got covid and attach a test result even if you have it. Why be vague?

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I did a few when I got covid, too. I mentioned I had contracted covid-19 and would be unable to make the deadline due to the illness and will need additional time for recovery.

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This thread is a great example of how much practices differ across jurisdictions, even with something as seemingly straightforward as a motion for extension of time. Probably best to check with someone who practices in your jurisdiction. Even better, someone with experience before your judge.

likesmart

Court is going to understand. Say an associate working on this matter contracted COVID-19 and will be unable to complete by the date.

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If you work at a large firm I may oppose this if I was on other side. It depends on the rhythm of the lit and if you have been an ass/needlessly aggressive. Like out of the several hundreds of lawyers working at your firm no one can cover?

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I hate this crap. Maybe if it's a simple hearing on a very routine motion. But I don't want someone unfamiliar with the case handling my summary judgment motion or a trial. When people say they need to be the one to handle the motion, brief, or hearing, I tend to believe them.

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I'd say you have covid (or, more generally are sick) and, due to this unforseen circumstance, you're uncertain if you will be able to submit whatever by the due date.

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Depending on the judge I would attach the positive test result. It’s insane that some of these judges are outright denying requests due to Covid

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If I recall, someone mentioned uploading the records to eCourts- am I making that up? Anyway it is definitely a best policy to tell HR you have COVID. We are still in a “pandemic” and the firm or office will likely want to do some sort of contact tracing.

Do you really need a motion for this? Can’t you submit to the judge an agreed extension with OC and a proposed order? I can’t believe OC wouldn’t agree to this with a consented order that you could probably do on presentment. But I guess I don’t know what jurisdiction you’re in.

helpful

I have seen this happen many times the last 6 months working for a judge. The attorneys have all said they are ill with COVID. I can find the exact verbiage (as in, phrasing, word choice, haha) if you want - if I recall, it’s usually a straightforward and courteous request

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