See Vision Point of Sale, Inc. v. Haas, 226 Ill.2d 334, 353 (2007) (holding that "what constitutes good cause," in the context of a motion for extension of time, "is factdependent and rests within the sound discretion of the circuit court"); see also Kilpatrick v. Baxter Healthcare Corp., 2023 IL App (2d) 230088, ¶ 15 (holding that a circuit court's ruling on a litigant's Rule 9(d)(2) motion is reviewed for an abuse of discretion).

¶ 19 We first address the parties' disagreement on the standard of review regarding the denial of a nunc pro tunc order. Defendants argue that the trial court's denial should be reviewed for an abuse of discretion, citing Kilpatrick v. Baxter Healthcare Corp., 2023 IL App (2d) 230088, ¶¶ 14-15, and O'Gara v. O'Gara, 2022 IL App (1st) 210013, ¶ 48. These cases used the abuse of discretion standard to review whether a party showed good cause pursuant to Illinois Supreme Court Rule 9(d)(2) (eff. Feb. 4, 2022) for an untimely filing.

An appellate court may not consider documents that are not part of the certified record on appeal, and attachments to appellate briefs that are not contained in the record on appeal cannot be used to supplement the record and are not properly before a reviewing court. Kilpatrick v. Baxter Healthcare Corp., 2023 IL App (2d) 230088, ¶ 11. References to evidence outside the record are not permitted and should be stricken.