You're talking about filing documents and arguments the other side has to respond to. The courts do NOT have patience for last-minute requests to bend procedure

You're talking about filing documents and arguments the other side has to respond to. The courts do NOT have patience for last-minute requests to bend procedure, because the side making a request wasn't acting in good faith. This isn't previously-unknown evidence being suddenly discovered. How many documents Apple has about this and how long it would take to go through them is stuff they could have known, should have known before this week.