A motion or stipulation to extend any date set by the discovery plan, scheduling order, or
other order must, in addition to satisfying the requirements of LR IA 6-1, be supported by a
showing of good cause for the extension. A motion or stipulation to extend a deadline set forth
in a discovery plan must be received by the court no later than 21 days before the expiration of
the subject deadline. A request made within 21 days of the subject deadline must be supported
by a showing of good cause. A request made after the expiration of the subject deadline will not
be granted unless the movant also demonstrates that the failure to act was the result of excusable
neglect. A motion or stipulation to extend a discovery deadline or to reopen discovery must
include:
(a) A statement specifying the discovery completed;
(b) A specific description of the discovery that remains to be completed;
(c) The reasons why the deadline was not satisfied or the remaining discovery was
not completed within the time limits set by the discovery plan; and
(d) A proposed schedule for completing all remaining discovery.
