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Why Bain over the other 2?
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Can you reach out to the other side for a joint stipulation on a briefing schedule that gives both sides extra time for the opp and reply? If the parties agree, then the court is more likely to grant it.
Agree with this. I don’t see there being an issue if you’re adjourning for the first time.
Coach
Ask OC to consent. I’ve consented to extensions for personal reasons many times before. It’s not childish or unprofessional in any way to ask. And people wonder why this profession is screwed up…
Even if it’s in federal court, just get OC to agree not to oppose a motion. You don’t have to give a reason to either OC or the court. Hell, I’ve waived an order compelling discovery responses when counsel finally called me and said he had been dealing with “family issues”. I’ve found 99/100 times, lawyers are generally going to grant the extension (within reason, not like a 1 month extension to reply to a motion) without asking questions.
“To be accommodated, you must first be accommodating.”
I can’t imagine you getting more time from the court or opposing counsel because of family time. It’s unfortunate but so unrealistic. If you can’t get help from a colleague to draft your opposition, start tomorrow and try to get through as much as possible before your grandparents arrive.
Or call OC and ask if they’ll agree to an extension. If they feel they are in a position to succeed in their motion, a few extra days won’t hurt.
Unless you’ve already had an extension, just propose a brief extension to opposing counsel. You don’t need to give a reason.
Not to be mean, but I’d guess there’s a 0% chance an extension is granted on those grounds. You’ll appear pretty childish/unprofessional requesting an extension on that basis as well. Your best option (as I’ve used) is to tap a fellow associate/attorney to handle it for you in exchange for your covering an MSJ/hearing/depo for them in the future. You can also bust your ass with a series of all-nighters and get it knocked out in advance. Sometimes, that’s what this profession requires.
Mentor
Hard disagree with this response. I have repeatedly sought extensions and continuances based on family commitments, including suspending a multi week bet the company jury trial for a day so I could fly home for my daughter’s 8th grade graduation. Family matters, especially now. A two week delay in filing a routine brief won’t change a thing. Missing this visit might haunt you for life.
Dealing with this issue starts with your relationship with opposing counsel. If you have been decent and professional, it is very unlikely that opposing counsel will refuse to stipulate to a two week extension. If you can file the motion on the post, just state that the basis of the unopposed motion is your need to “address a personal situation.” If you cannot secure the opposing party’s stipulation,  then file the motion, explain the circumstances, and hope that the judge will understand the motion, in context (e.g. you haven’t seen your elderly grandparents in more than a year because of the pandemic), and grant it. In either case I see zero downside in making the request. The judge isn’t going to think of you as “childish.” In fact, the judge will forget the motion within a few hours of deciding it. 
I would tie it to discovery. Has all discovery been turned from the parties? Or propounded? Depos been taken? File an extension because SJM is premature.
I’d get to work opposing. Ask for a stipulated extension—offer them something if you have anything to offer. No one wins MSJs, they know this. Ask for an extension in an email. Try to articulate why more discovery is needed. While reviewing the evidence you’ve determined that more discovery is needed. Articulate the discovery. Ask for an extension. Then if the refuse you will cite to their email in your opp in the section where you seek an extension for further discovery.
I just drafted 5 oops due 1 week apart from the other. Argue they did not meet their burden of persuasion or production. Dispute all of their facts. And just prove to the court that it needs to go to a jury.
What state are you in? If you’re in CA I can give you a rock solid template.
It can be done in a few solid days if you aren’t trying to piece together hundreds of exhibits
I’ve requested numerous stipulated continuances with OC simply citing a busy schedule. Often times especially now, because of his impacted the courts have been, so many hearings, deadlines and depos are overlapping that it’s so common to get an extension. Very rare is OC not amenable.
Well you are one of the good ones! No, we just tend to come up against the attorneys who know they have bad facts and don’t have any other tricks but to delay and distract. Perjury is common, misquoting case law is common, all of the dirty lawyer tricks.
And sometimes family comes first. Work can wait. We have extensions for a reason. Ask for it. Or assign the task to someone else. Spend time with your family. Or, pull a nighter before hand and ask another atty to appear at the motion hour.
I agree re stipulation with opposing counsel.
Reach out with a phone call and appeal to their humanity
What court are you in? Two week adjournments are routine in NJ state court, nothing more than your adversaries consent is required to do so.
I have also seen courts willing to postpone deadlines for family matters given the pandemic, you could attempt to be upfront and at worst they reject the request
Actually fairly simple. Call opposing counsel and be honest. Present Court with consent motion for continuance and proposed Order.
So what happened here?
I’ve worked for many judges at a staff attorney and every one of them would have granted a 7-10 day briefing extension for this reason.