It is not enough for counsel to claim that s/he is too busy to meet the deadline, has plans to be on vacation, wants more time to study the record, or was only recently added to the client's team of lawyers. Such assertions, inasmuch as they turn on factors within the control of counsel or the client, can be raised in most any case and generally do not justify extending the deadline for certiorari review. Rather, unforeseen or uncontrollable events (e.g., a death in the family, illness, or active engagement at trial) lie at the heart of the "good cause" requirement for additional time to seek certiorari.

Joseph v. Hess Oil Virgin Islands Corp., No. 11-8026, slip op. at 17 (3d Cir. July 6, 2011) (Smith, J.) (holding that Hess Oil's reason for needing more time to file certiorari petition — the advent of new counsel — to Supreme Court did not satisfy "good cause" test but granting request due to "absence of prior guidance" on question).