We were having dinner with a friend of ours last night (he's an East Coast partner), and he mentioned how frustrated he was by new lawyers who didn't seem to understand how deadlines are supposed to work. To him (and to us), a deadline for a court filing means that the document needs to be finished a couple of days before the filing deadline, to allow for last-minute emergencies.
Want to impress your boss? Get the draft ready long before the deadline, so that you have time to polish it before it's due. Proofread the document carefully; you don't want your mistake to get publicity like this. We call those news stories "career-limiting moves."
We guarantee you: wait until the last minute, and Murphy's Law will ensure that you can't file the darn thing on time. ECF will go down; FedEx will misdeliver the document; an earthquake will close the courthouse. (Each of these things has happened to Nancy.)
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