Form 1-204.3 Ex Parte Motion [ ^ ] ,[and spouse] * * Plaintiff(s) * * v. * * [ ^ ] * * Defendant(s) * * * * * * * * * * * * * * * * * * * IN THE [CIRCUIT/DISTRICT] COURT FOR [ ^ ] Civil No.

[ ^ ] * * * * * * * * * * * * * * *

Ex Parte Motion to Shorten Time Requirements [ ^ ], defendant, pursuant to Rule 1-204(b) moves ex parte for an order shortening the time in which the plaintiff shall respond to its motion to strike the plaintiff's amended complaint. As grounds for this motion, defendant says: 1. The trial of this case is scheduled to commence before a jury on [ ^ ], 19[ ^ ]. 2. Today, [ ^ ], 19[ ^ ], defendant received the plaintiff's amended complaint which articulates for the first time in this action a new theory of liability against defendant. 3. Contemporaneous with the filing of this motion, defendant has filed a motion to strike the plaintiff's amended complaint. 4. Unless the time for plaintiff's response to defendant's motion to strike is shortened to [ ^ ], 19[ ^ ], plaintiff's response would not be due until shortly before trial. Rule 2-311(b). 5. Today defendant's counsel by telephone requested plaintiff's counsel to voluntarily submit to a shortened response time for defendant's motion to strike the amended complaint, however, plaintiff's counsel refused to agree. 6. Defendant's counsel then stated defendant's intention to file the instant motion seeking a Court-ordered shortening of the response time, and further stated that it would be presented to the motions judge for immediate hearing and ruling today.

Plaintiff's counsel stated that he would not be present at such a Court conference due to previously scheduled commitments. 7. Unless the Court grants ex parte the relief requested, defendant will be prejudiced by resolution of its motion to strike the amended complaint under the current timetable given the imminent trial date. WHEREFORE, defendant moves for an order shortening the time to [ ^ ], 19[ ^ ] in which plaintiff shall respond to defendant's motion to strike the amended complaint.

[ ^ ] [Address and Telephone] Attorney for Defendant [Insert Request for Hearing, if any: File 2-311-01] Certificate of Service I HEREBY CERTIFY that on this [ ^ ] day of [ ^ ], 19[ ^ ], the aforegoing Ex Parte Motion to Shorten Time Requirements was [ ^ ] to [ ^ ] at [ ^ ].

[ ^ ] Attorney for [ ^ ]