Holding that parallel litigation on straightforward contract dispute with primary importance only to the immediate parties did not provide any weight for the piecemeal litigation factor
In NLRB v. Washington Star Co., 732 F.2d 974 (D.C. Cir. 1984), exceptions were allowed to be accepted one day late where the Respondent made a good faith effort to comply, the delay was considered "de minimis" and did not result in prejudice to the other party.
In NLRB v. Central Mercedita, Inc., 273 F.2d 370 (1st Cir. 1959), the First Circuit held that the Board had acted arbitrarily in defaulting a party because its exceptions were filed "only two days late".