Case 1:20-cv-03590-JEB Document 74 Filed 07/23/21 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
FEDERAL TRADE COMMISSION,
Plaintiff,
Civil Action No. 1:20-cv-03590 (JEB)
v.
FACEBOOK, INC.
Defendant.
FEDERAL TRADE COMMISSION’S UNOPPOSED MOTION FOR AN EXTENSION
OF TIME TO FILE AN AMENDED COMPLAINT
On June 28, 2021, the Court dismissed Plaintiff Federal Trade Commission’s complaint
without prejudice, and provided Plaintiff until July 29, 2021 to file an amended complaint. ECF
No. 72. Pursuant to Federal Rule of Civil Procedure 6(b)(1), Plaintiff respectfully moves this
Court for an extension of time of 21 days until August 19, 2021 to file an amended complaint.
Pursuant to Local Civil Rule 7(m), Plaintiff conferred with counsel for Defendant Facebook, Inc.
(“Facebook”) regarding this requested extension, and Facebook does not oppose this motion,
subject to the following understandings.
First, the parties have agreed to the following proposed schedule related to Facebook’s
response to an amended complaint: (1) Plaintiff shall file an amended complaint no later than
August 19, 2021; (2) Facebook shall file its answer or otherwise respond to Plaintiff’s amended
complaint by October 4, 2021; (3) Plaintiff shall file its opposition to Facebook’s motion to
dismiss, if any, by November 17, 2021; and (4) Facebook shall file its reply, if any, by December
1, 2021. Second, Facebook reserves all rights as to the adequacy, legal validity, and
appropriateness of any proposed amendment.
Case 1:20-cv-03590-JEB Document 74 Filed 07/23/21 Page 2 of 3
Plaintiff respectfully submits that good cause exists to extend until August 19, 2021 the
deadline to file an amended complaint. See Fed. R. Civ. P. 6(b)(1) (the Court may for good
cause grant requests for time extension made before the original time expires). The requested
extension will provide sufficient time for Plaintiff to complete internal agency processes with
respect to filing an amended complaint. Further, the parties have agreed to a schedule for a
response to the amended complaint and any necessary briefing thereafter as described above.
The modest extensions requested will not burden or prejudice Defendant or any third parties, and
are consistent with the just, speedy, and inexpensive determination of this action. See Fed. R.
Civ. P. 1.
For the foregoing reasons, Plaintiff respectfully requests that the Court grant this motion.
DATED: July 23, 2021 Respectfully submitted,
/s/ Krisha Cerilli
Krisha Cerilli (D.C. Bar 983281)
Federal Trade Commission
Bureau of Competition
400 Seventh Street, SW
Washington, DC 20024
Telephone: (202) 326-3337
Email: kcerilli@[Link]
Attorney for Plaintiff
Federal Trade Commission
2
Case 1:20-cv-03590-JEB Document 74 Filed 07/23/21 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on July 23, 2021, I authorized the electronic filing of the foregoing
with the Clerk of the Court using the CM/ECF system, which will send a Notice of Electronic
Filing to all counsel of record.
/s/ Krisha Cerilli
Krisha Cerilli (D.C. Bar 983281)
Federal Trade Commission
Bureau of Competition
400 Seventh Street, SW
Washington, DC 20024
Telephone: (202) 326-3337
Email: kcerilli@[Link]
Attorney for Plaintiff
Federal Trade Commission
3
Case 1:20-cv-03590-JEB Document 74-1 Filed 07/23/21 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
FEDERAL TRADE COMMISSION,
Plaintiff,
Civil Action No. 1:20-cv-03590 (JEB)
v.
FACEBOOK, INC.
Defendant.
[PROPOSED] ORDER GRANTING FEDERAL TRADE COMMISSION’S MOTION
FOR AN EXTENSION OF TIME
Upon consideration of Plaintiff Federal Trade Commission’s Motion for an Extension of
Time to File an Amended Complaint, the consent motion is GRANTED. Accordingly, (1)
Plaintiff shall file an amended complaint by August 19, 2021; (2) Defendant shall file its answer
or otherwise respond to Plaintiff’s amended complaint by October 4, 2021; (3) Plaintiff shall file
its opposition to Defendant’s motion to dismiss, if any, by November 17, 2021; and (4)
Defendant shall file its reply, if any, by December 1, 2021.
IT IS SO ORDERED.
Dated: _____________, 2021 _____________________
James E. Boasberg
United States District Judge
Case 1:20-cv-03590-JEB Document 74-1 Filed 07/23/21 Page 2 of 2
ATTORNEYS TO BE NOTIFIED
Plaintiff Daniel J. Matheson (D.C. Bar No. 502490)
Federal Trade Commission
600 Pennsylvania Ave, NW
Washington, DC 20580
Tel: 202-326-2075
dmatheson@[Link]
Defendant Mark C. Hansen (D.C. Bar No. 425930)
Kellogg, Hansen, Todd,
Figel & Frederick, P.L.L.C.
1615 M Street, N.W., Suite 400
Washington, D.C. 20036
Tel: (202) 326-7900
mhansen@[Link]
