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 RESPONSE TO DEFENDANTS BF LABS INC.,
SONNY VLEISIDES, AND DARLA DRAKE’S RESPONSE AND OBJECTIONS TO

TEMPORARY RECEIVER’S SUBMISSION UNDER SEAL OF REDACTED BILLING
STATEMENTS

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 Response to Defendants BF Labs Inc., Sonny Vleisides, and Darla Drake’s (the
“Defendants”) Response and Objections to Temporary Receiver’s Submission Under Seal of
Redacted Billing Statements (the “Response’’), Temporary Receiver states as follows:

1. On May 22, 2015, the Court entered its Order approving the Temporary
Receiver’s proposed redactions of his billing statements and directing the same to be served upon
Defendants by no later than May 28, 2015. See Doc. 314. Defendants had ten days from the date
of filing the proposed objections to file the Response.

2. On May 22, 2015, the Temporary Receiver promptly filed his proposed redactions
and emailed the same to counsel for the Defendants. See Doc. 317.

a On May 27, 2015, with the consent of the Temporary Receiver, the Defendants’

sought an extension of their response deadline to June 5, 2015. Additionally, given a family

WA 7038491.1

Case 4:14-cv-00815-BCW Document 331 Filed 06/15/15 Page 1 of 3

wedding, the Temporary Receiver requested, and Defendants agreed, that the Temporary
Receiver would have until June 17, 2015 in order to filed his reply. The Court approved such
extensions on May 27, 2015. See Doc. 322.

4. On Friday, June 5, 2015, Defendants filed the Response under seal. The Response
was provided to the Temporary Receiver at approximately 8:00 p.m.

of Since the receipt of the Response, the Temporary Receiver has been diligently
working on his reply. However, as referenced above, the Temporary Receiver was recently out
of town for a family matter that prevented him from fully focusing on the Response for several
days. Additionally, several other unexpected scheduling challenges, both personal and business
related, have presented themselves to the Temporary Receiver and his counsel after receipt of the
Response.

6. Temporary Receiver takes the Response very seriously and wants to fully address
the same. Accordingly, the Temporary Receiver requests that the Court issue an Order granting
him to and including June 24, 2015, in which to file his reply to the Response.

ve This motion is not made for the purpose of delay or harassment, and no party will

be prejudiced if the motion is granted.

8. Counsel for the Defendants was contacted and do not object to the relief
requested.
9. 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.

2 WA 7038491.1

Case 4:14-cv-00815-BCW Document 331 Filed 06/15/15 Page 2 of 3

WHEREFORE, Temporary Receiver respectfully requests that the Court grant
Temporary Receiver to and including June 24, 2015, in which to file his Reply to the Response,

and for such other and further relief that the Court deems just and appropriate.

Respectfully Submitted,

SPENCER FANE BRITT & BROWNE LLP

/s/_ Bryant T. Lamer
Bryant T. Lamer MO #57355

Andrea M. Chase MO #66019
1000 Walnut Street, Suite 1400
Kansas City, MO 64106

Telephone: (816) 474-8100
Facsimile: (816) 474-3216
blamer@ spencerfane.com

achase @ spencerfane.com
ATTORNEYS FOR TEMPORARY
RECEIVER ERIC L. JOHNSON

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the 15th day of June, 2015, 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/ Bryant T. Lamer
Attorney for Temporary Receiver Eric L.
Johnson

3 WA 7038491.1

Case 4:14-cv-00815-BCW Document 331 Filed 06/15/15 Page 3 of 3