I am the defendant in a small claims case for a credit card debt. I am working on discovery right now and need to file an extension to ensure I actually have time to review the Plaintiff's documents, etc before the hearing. Please examine my request below and offer any insights to changes that should made or thoughts on how I could make it better.


Comes now the defendant pro se,Jane Doe, and moves the Court for an extension of time of at least sixty (60) days from the hearing date in this matter currently scheduled for hearing on February 23, 2011. As grounds for this motion, the defendant states:

1 ) I have served requests for discovery on the Plaintiff's attorney on February 16th, 2011 via certified mail.

2) The rules don't ensure that I will have those answers by our current scheduled hearing date of February 23, 2011; therefore, I ask the court for additional time to complete discovery.

3) I would also need additional time to examine and review the Plaintiff's answers once they are received.

4) I am appearing pro se, because I cannot afford an attorney to represent me at this time. I am a full time working mother with two small children and therefore my free time to work on this case is limited. Because of my limited time and resources, I need additional time to research and prepare for the hearing following the discovery period to prepare a fair defense.