"Your Honor, my schedule is incredibly busy over the next several weeks. I'd like an extended time to respond to opposing counsel's Motion. If the Court would allow it, I would respect that I get 45 days to file my brief"
Day One: Return from court. Tell the partner the good news. Forget to docket order in my personal schedule. Return file to bottom drawer of file cabinet. Close file cabinet.
Day Seven: File has moved from bottom drawer of my file cabinet to the bottom drawer of the file storage room. I've got 38 more days to worry about this thing. Why would I want to start working on this case?
Day Twenty: Completely forget about: (1) This case, (2) This motion (3) The opposing counsel and (4) his really bad suits.
Day Twenty Nine: What brief?
Day Thirty Five: Client calls twice, e-mails and then calls again. Wants a status update. Unable to answer the question, I tell the client that I will pull the file and try and get back to her later in the day.
Day Thirty Seven: Client calls again. I tell the secretary that "I'm in court"
Day Thirty Nine: Call client. "Everything's fine! We'll be in court in a couple of weeks and I'll let you know what's going on"
Day Forty: Pull file. Realize that you have completely forgotten about this pending Motion. Schedule emergency meeting with Partner to plot strategy. Find out that he is out of the office until tomorrow. Begin researching any and all potential legal rebuttals to opposing counsel's argument
Day Forty One: Panic.
Day Forty Two: Meet with Partner. Discuss strategy. In 15 seconds. As he is walking out the door for the weekend.
Day Forty Three: Saturday. Wake up at 6:15. Start work. Break for appropriate sporting events. Break for dinner. Work until late. Showering forbidden.
Day Forty Four: Sunday. Ignore the fact that you are less than 25% complete with your brief. Go to Bears Game. Watch them lose to the Green Bay Packers. Drink the pain away.
Day Forty Five: DEADLINE DAY. Wake up earlier than normal after a fitful night's sleep. Get to the office early. Find memoranda from your partner regarding stupid shit. Find voicemail from your partner regarding stupider shit. Find yourself finding everything that everyone tells you is stupid shit. Realize that you have a very short fuse today. Move from desk (where you can be found) to empty conference room (where it's much less likely that you will be found). Write. All. Day. Do not leave until it is done.
Day Forty Five: 5pm TECHNICAL DEADLINE FOR SERVICE. Still writing. Whoops.
Day Forty Five: 7pm Finish Writing. Call Partner waiting for approval to serve.
Day Forty Five: 9pm Partner Sends a Text Message. "I don't need to look at it. I trust you. Send it."
Day Forty Five: 10pm. Three drinks in. Sends out brief.