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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
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`FEDERAL TRADE COMMISSION,
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`Plaintiff,
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`v.
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`Defendant.
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`Civil Action No. 1:20-cv-03590 (JEB)
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`FACEBOOK, INC.
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`FEDERAL TRADE COMMISSION’S UNOPPOSED MOTION FOR AN EXTENSION
`OF TIME TO FILE AN AMENDED COMPLAINT
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`On June 28, 2021, the Court dismissed Plaintiff Federal Trade Commission’s complaint
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`without prejudice, and provided Plaintiff until July 29, 2021 to file an amended complaint. ECF
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`No. 72. Pursuant to Federal Rule of Civil Procedure 6(b)(1), Plaintiff respectfully moves this
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`Court for an extension of time of 21 days until August 19, 2021 to file an amended complaint.
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`Pursuant to Local Civil Rule 7(m), Plaintiff conferred with counsel for Defendant Facebook, Inc.
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`(“Facebook”) regarding this requested extension, and Facebook does not oppose this motion,
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`subject to the following understandings.
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`First, the parties have agreed to the following proposed schedule related to Facebook’s
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`response to an amended complaint: (1) Plaintiff shall file an amended complaint no later than
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`August 19, 2021; (2) Facebook shall file its answer or otherwise respond to Plaintiff’s amended
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`complaint by October 4, 2021; (3) Plaintiff shall file its opposition to Facebook’s motion to
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`dismiss, if any, by November 17, 2021; and (4) Facebook shall file its reply, if any, by December
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`1, 2021. Second, Facebook reserves all rights as to the adequacy, legal validity, and
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`appropriateness of any proposed amendment.
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`Case 1:20-cv-03590-JEB Document 74 Filed 07/23/21 Page 2 of 3
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`Plaintiff respectfully submits that good cause exists to extend until August 19, 2021 the
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`deadline to file an amended complaint. See Fed. R. Civ. P. 6(b)(1) (the Court may for good
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`cause grant requests for time extension made before the original time expires). The requested
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`extension will provide sufficient time for Plaintiff to complete internal agency processes with
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`respect to filing an amended complaint. Further, the parties have agreed to a schedule for a
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`response to the amended complaint and any necessary briefing thereafter as described above.
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`The modest extensions requested will not burden or prejudice Defendant or any third parties, and
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`are consistent with the just, speedy, and inexpensive determination of this action. See Fed. R.
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`Civ. P. 1.
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`For the foregoing reasons, Plaintiff respectfully requests that the Court grant this motion.
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`Respectfully submitted,
`/s/ Krisha Cerilli
`Krisha Cerilli (D.C. Bar 983281)
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`Federal Trade Commission
`Bureau of Competition
`400 Seventh Street, SW
`Washington, DC 20024
`Telephone: (202) 326-3337
`Email: kcerilli@ftc.gov
`Attorney for Plaintiff
`Federal Trade Commission
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`DATED: July 23, 2021
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`Case 1:20-cv-03590-JEB Document 74 Filed 07/23/21 Page 3 of 3
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`CERTIFICATE OF SERVICE
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`I hereby certify that on July 23, 2021, I authorized the electronic filing of the foregoing
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`with the Clerk of the Court using the CM/ECF system, which will send a Notice of Electronic
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`Filing to all counsel of record.
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`/s/ Krisha Cerilli
`Krisha Cerilli (D.C. Bar 983281)
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`Federal Trade Commission
`Bureau of Competition
`400 Seventh Street, SW
`Washington, DC 20024
`Telephone: (202) 326-3337
`Email: kcerilli@ftc.gov
`Attorney for Plaintiff
`Federal Trade Commission
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`3
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