IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI FEDERAL TRADE COMMISSION, ) Plaintiff, v. Case No. 4:14-CV-00815-BCW BF LABS INC., et al., Defendants, TEMPORARY RECEIVER’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY SUGGESTIONS IN SUPPORT OF SECOND APPLICATION FOR ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND REIMBURSEMENT OF ACTUAL AND NECESSARY EXPENSES COMES NOW Temporary Receiver Eric L. Johnson (“Temporary Receiver”) and moves that the Court enter an order extending the deadline for Temporary Receiver to file his Reply Suggestions in Support of his Second Application for Allowance of Compensation for Services Rendered and Reimbursement of Actual and Necessary Expenses for the Period November 1 through November 30, 2014, by ten days, up to and including January 9, 2015. In support of this motion, Temporary Receiver states as follows: 1. On December 18, 2014, Temporary Receiver filed his Second Application for Allowance of Compensation for Services Rendered and Reimbursement of Actual and Necessary Expenses for the Period November 1 through November 30, 2014 (“Second Application’). Doc. 2.12. 2. Defendant BF Labs, Inc. (“BFL”) filed its opposition to Temporary Receiver’s Second Application on December 24, 2014. 3. Plaintiff Federal Trade Commission (“FTC”) did not file an opposition to Temporary Receiver’s Second Application. WA 6484026. 1 Case 4:14-cv-00815-BCW Document 221 Filed 12/29/14 Page 1 of 3 4, The Standing Order (Doc. 77) provides that reply suggestions may be filed within three (3) business days from the time suggestions in opposition are filed. s: Under the Standing Order, Temporary Receiver’s reply suggestions are due on December 30, 2014, given the Christmas holiday. 6. The Standing Order allows the Court to extend the time limits for good cause. Doc. 77 at 2. a Good cause exists for an extension for filing of the reply suggestions, given Temporary Receiver’s continued work to wind down the receivership in accordance with the Court’s December 23, 2014 Order (Doc. 218) and the fact that the opposition and reply brief due dates occur during the holidays. 8. Temporary Receiver accordingly requests that the Court issue an Order granting a ten-day extension of time, to and including January 9, 2015, in which to file his Reply Suggestions in Support of the Second Application. = This motion is not made for the purpose of delay or harassment, and no party will be prejudiced if the motion is granted. 10. Counsel for BFL does not oppose the requested relief. 11. Pursuant to the Court’s Standing Order (Doc. 77), a proposed order in Word format granting the relief requested herein is being submitted to the Court by email to joella_baldwin @ mow.uscourts.gov. WHEREFORE, Temporary Receiver respectfully requests that the Court grant Temporary Receiver a ten-day extension of time, to and including January 9, 2015, in which to file his Reply Suggestions in Support of the Second Application (Doc. 212). 2 WA 6484026. 1 Case 4:14-cv-00815-BCW Document 221 Filed 12/29/14 Page 2 of 3 Respectfully Submitted, SPENCER FANE BRITT & BROWNE LLP /s/ Lucinda H. Luetkemeyer Bryant T. Lamer MO #57355 Lisa Epps Dade MO #48580 Andrea M. Chase MO #66019 Lucinda H. Luetkemeyer MO #63983 1000 Walnut Street, Suite 1400 Kansas City, MO 64106 Telephone: (816) 474-8100 Facsimile: (816) 474-3216 blamer@ spencerfane.com lepps @ spencerfane.com achase @ spencerfane.com lluetkemeyer @spencerfane.com ATTORNEYS FOR TEMPORARY RECEIVER ERIC L. JOHNSON CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 29th day of December, 2014, a true and correct copy of the foregoing was filed electronically with the United States District Court for the Western District of Missouri using the CM/ECF system, which sent notification to all parties of interest participating in the CM/ECF system. /s/ Lucinda H. Luetkemeyer Attorney for Temporary Receiver Eric L. Johnson 3 WA 6484026. 1 Case 4:14-cv-00815-BCW Document 221 Filed 12/29/14 Page 3 of 3