UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION

FEDERAL TRADE COMMISSION, CASE NO. 4:14-cv-00815-BCW
Plaintiff,
Vv.

BF LABS, INC., et al.

Defendants.

PLAINTIFF’S MOTION TO EXTEND TEMPORARY RESTRAINING ORDER

Plaintiff, Federal Trade Commission (“FTC”), respectfully moves the Court, pursuant to
Federal Rule of Civil Procedure 65, to extend the temporary restraining order (“TRO” or
“Order’) the Court issued on September 18, 2014. The FTC requests that the TRO remain in
effect until 11:59 o’clock p.m. on the 29th day of September 29, 2014, or until the Court issues
its ruling following the preliminary injunction hearing in this matter. In support of this Motion,
Plaintiff states as follow:

1. As specified in section XXV of the TRO, the Order is set to expire at 9:00 o’clock
a.m. on the 29th day of September, 2014. Further, as ordered in Section XXII of the TRO, the
parties are appearing before this Court on the 29" day of September, 2014, at 9:00 o’clock a.m.
for a preliminary injunction hearing.

2 Because the dissipation, destruction, or concealment of assets and records would

frustrate the Court’s ability to award effective final relief for the consumer victims of

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Defendants’ unlawful practices, the FTC would request entry of an order to extend the TRO
pending the outcome of the preliminary injunction hearing.

WHEREFORE, Plaintiff requests that the Court extend the temporary restraining order
issued on September 18, 2014, until 11:59 p.m. on September 29, 2014, or until the Court issues

its ruling following the preliminary injunction hearing.

Respectfully submitted,

JONATHAN E. NUECHERTERLEIN
General Counsel

Dated: September 28, 2014 /s/ Teresa Kosmidis
Helen Wong, DC Bar # 997800
Teresa N. Kosmidis, NY Bar# 4533824
Leah Frazier, DC Bar# 492540492540
Federal Trade Commission
600 Pennsylvania Ave., N.W.
Mail Stop CC-10232
Washington, D.C. 20580
202-326-3779 (Wong)
202-326-3216 (Kosmidis)
202-326-2187 (Frazier)
Facsimile: 202-326-3768
hwong @ftc.gov
tkosmidis @ftc.gov
Ifrazier@ftc.gov

TAMMY DICKINSON
United States Attorney

Dated: September 28, 2014 /s/ Charles M. Thomas
Charles M. Thomas, MO Bar #28522
Assistant United States Attorney
Charles Evans Whittaker Courthouse
400 East Ninth Street, Room 5510

Z

Case 4:14-cv-00815-BCW Document 45 Filed 09/28/14 Page 2 of 3

Kansas City, MO 64106
Telephone: (816) 426-3130
Facsimile: (816) 426-3165
E-mail: charles.thomas @usdoj.gov

Attorneys for Plaintiff
FEDERAL TRADE COMMISSION

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