STYLETHREAD -- LET'S TALK SHOP!

It is monday morning and my brain is not yet working properly...i would love some imput

i am trying to come up with some language to plug into a proposed order.  we requested an extension of all deadlines in a case...the judge reluctantly granted it and stated that "unless moses comes down from the mountain"  there would be no more extensions.  she stated that she was trying to come up with some language to put in the scheduling order that would stress that any additional extensions would only be granted "for something more than good cause shown"

the counsel for the other side has proposed "exceptional circumstances"...i would like something a little less strict...

what about: "the amended deadlines are set by the court and are final, notwithstanding a showing of need in excess of good cause that would necessitate a continuance" 

OR...I thought about just using language that wouldn't really lay out a burden, but just leave it up to the court

does anyone have that magic language that i am looking for?  if my scenario needs more facts or you need some clarification, let me know.