In Brill v. City of New York (2 NY3d 648, 814 N.E.2d 431, 781 N.Y.S.2d 261 [2004] ), the Court of Appeals made clear that the statutory deadline should be strictly enforced, in order to prevent the filing of "eleventh-hour summary judgment motions," a practice that "ignores statutory law, disrupts trial calendars, and undermines the goals of orderliness and efficiency in state court practice" (Fofana v. 41 West 34th Street, LLC, 71 AD3d 445, 897 N.Y.S.2d 46 [1st Dept 2010] citing Brill at 650-651, 781 NYS2d 261). It concluded that the "good cause" called for by CPLR 3212(a) requires a "satisfactory explanation for the untimeliness-rather than simply permitting meritorious, nonprejudicial filings, however tardy" (Fofana, citing Brill at 652, 781 NYS2d 261). The First Department observed that "courts may not excuse a late motion, no matter how meritorious, upon a perfunctory claim of law office failure" (Fofana citing Azcona v. Salem, 49 AD3d 343, 343, 852 N.Y.S.2d 767 [2008]).