(a) Motion to Extend a Scheduling Deadline. A party may move to extend a deadline
established by a scheduling order. The motion must:
1. Demonstrate a specific need for the requested extension; and
2. Contain a detailed proposed amendment to the previously entered scheduling
order. For motions to extend the deadline for completion of all discovery, the
remaining discovery must be specifically described and scheduled, e.g., the
motion must provide the names of each remaining deponent and the date, time,
and place of each remaining deposition; and
3. State the position of opposing counsel as to the requested extension.
(b) Standard for Granting an Extension of a Scheduling Deadline. The Court may
grant a Rule 16.3(a) motion only upon a showing of good cause. Further, the Court
may extend the deadline for completion of all discovery only if:
1. There has been active discovery; or
2. The moving party demonstrates that disabling circumstances precluded active
discovery.