MOTION for Extension of Time to Respond to Motion to Seal (Unopposed) by Commonwealth of Virginia, State of Arizona, State of California, State of Colorado, State of Connecticut, State of Illinois, State of Michigan, State of Minnesota, State of Nebraska, State of New Hampshire, State of New Jersey, State of New York, State of North Carolina, State of Rhode Island, State of Tennessee, State of Washington, State of West Virginia, United States of America. (Attachments: # (1) Proposed Order)(Teitelbaum, Aaron)
Page 1 PageID#
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
v.
GOOGLE LLC,
Defendant.
)
)
)
)
)
)
)
)
No. 1:23-cv-00108-LMB-JFA
PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO
GOOGLE’S MOTION TO SEAL AT ECF NO. 1.
Google filed its response to Plaintiffs’ Motion for Partial Judgment on the
Pleadings on August 31, 2023. ECF Nos. 368-69.
2.
Attached to that response were 18 exhibits that Google submitted provisionally
under seal pursuant to the terms of the operative Protective Order in this matter. Google’s
memorandum in support of its Motion to Seal indicates that it would not be seeking to maintain
these exhibits under seal absent the Protective Order. ECF No. 370, at 1.
3.
Plaintiffs’ response to the motion to seal is currently due on September 7, 2023.
Pursuant to Local Rule 5, Plaintiffs must articulate a basis for retaining any portion of the exhibits
under seal.
4.
Due to the volume of the exhibits and the fact that certain exhibits involve
information from third parties, Plaintiffs respectfully request an extension of one week, until
September 14, 2023, to respond to Google’s motion to seal to complete the analysis of what
material Plaintiffs believe should remain under seal, and what material can be publicly docketed.
5.
Plaintiffs submit that good cause exists to grant this extension, as Plaintiffs have
proceeded diligently in this matter, no party will be prejudiced by the requested relief, and thePage 2 PageID#
requested relief will not affect any other deadlines in this case. See generally Roe v. Howard, No.
1:16-cv-562, 2017 U.S. Dist. LEXIS 187258, *1-2 (E.D. Va. June 30, 2017).
6.
Plaintiffs have met and conferred with Google regarding this motion. Google
informed Plaintiffs that it does not oppose the relief requested herein.
Dated: September 6, Respectfully submitted,
JESSICA D. ABER
United States Attorney
JASON S. MIYARES
Attorney General of Virginia
/s/ Gerard Mene
GERARD MENE
Assistant U.S. Attorney
2100 Jamieson Avenue
Alexandria, VA Telephone: (703) 299-Facsimile: (703) 299-Email: Gerard.Mene@usdoj.gov
/s/ Andrew N. Ferguson
ANDREW N. FERGUSON
Solicitor General
STEVEN G. POPPS
Deputy Attorney General
TYLER T. HENRY
Assistant Attorney General
/s/ Julia Tarver Wood
JULIA TARVER WOOD
/s/ Aaron M. Teitelbaum
AARON M. TEITELBAUM
United States Department of Justice
Antitrust Division
450 Fifth Street NW, Suite Washington, DC Telephone: (202) 307-Fax: (202) 616-Email: Julia.Tarver.Wood@usdoj.gov
Attorneys for the United States
Office of the Attorney General of Virginia
202 North Ninth Street
Richmond, VA Telephone: (804) 692-Facsimile: (804) 786-Email: thenry@oag.state.va.us
Attorneys for the Commonwealth of
Virginia and local counsel for the
States of Arizona, California,
Colorado, Connecticut, Illinois,
Michigan, Minnesota, Nebraska, New
Hampshire, New Jersey, New York,
North Carolina, Rhode Island,
Tennessee, Washington, and West
Virginia
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 392 Filed 09/06/23 Page 1 of 2 PageID# 5981
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
v.
GOOGLE LLC,
Defendant.
)
)
)
)
)
)
)
)
No. 1:23-cv-00108-LMB-JFA
PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO
GOOGLE’S MOTION TO SEAL AT ECF NO. 370
1.
Google filed its response to Plaintiffs’ Motion for Partial Judgment on the
Pleadings on August 31, 2023. ECF Nos. 368-69.
2.
Attached to that response were 18 exhibits that Google submitted provisionally
under seal pursuant to the terms of the operative Protective Order in this matter. Google’s
memorandum in support of its Motion to Seal indicates that it would not be seeking to maintain
these exhibits under seal absent the Protective Order. ECF No. 370, at 1.
3.
Plaintiffs’ response to the motion to seal is currently due on September 7, 2023.
Pursuant to Local Rule 5, Plaintiffs must articulate a basis for retaining any portion of the exhibits
under seal.
4.
Due to the volume of the exhibits and the fact that certain exhibits involve
information from third parties, Plaintiffs respectfully request an extension of one week, until
September 14, 2023, to respond to Google’s motion to seal to complete the analysis of what
material Plaintiffs believe should remain under seal, and what material can be publicly docketed.
5.
Plaintiffs submit that good cause exists to grant this extension, as Plaintiffs have
proceeded diligently in this matter, no party will be prejudiced by the requested relief, and the
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 392 Filed 09/06/23 Page 2 of 2 PageID# 5982
requested relief will not affect any other deadlines in this case. See generally Roe v. Howard, No.
1:16-cv-562, 2017 U.S. Dist. LEXIS 187258, *1-2 (E.D. Va. June 30, 2017).
6.
Plaintiffs have met and conferred with Google regarding this motion. Google
informed Plaintiffs that it does not oppose the relief requested herein.
Dated: September 6, 2023
Respectfully submitted,
JESSICA D. ABER
United States Attorney
JASON S. MIYARES
Attorney General of Virginia
/s/ Gerard Mene
GERARD MENE
Assistant U.S. Attorney
2100 Jamieson Avenue
Alexandria, VA 22314
Telephone: (703) 299-3777
Facsimile: (703) 299-3983
Email: Gerard.Mene@usdoj.gov
/s/ Andrew N. Ferguson
ANDREW N. FERGUSON
Solicitor General
STEVEN G. POPPS
Deputy Attorney General
TYLER T. HENRY
Assistant Attorney General
/s/ Julia Tarver Wood
JULIA TARVER WOOD
/s/ Aaron M. Teitelbaum
AARON M. TEITELBAUM
United States Department of Justice
Antitrust Division
450 Fifth Street NW, Suite 7100
Washington, DC 20530
Telephone: (202) 307-0077
Fax: (202) 616-8544
Email: Julia.Tarver.Wood@usdoj.gov
Attorneys for the United States
Office of the Attorney General of Virginia
202 North Ninth Street
Richmond, VA 23219
Telephone: (804) 692-0485
Facsimile: (804) 786-0122
Email: thenry@oag.state.va.us
Attorneys for the Commonwealth of
Virginia and local counsel for the
States of Arizona, California,
Colorado, Connecticut, Illinois,
Michigan, Minnesota, Nebraska, New
Hampshire, New Jersey, New York,
North Carolina, Rhode Island,
Tennessee, Washington, and West
Virginia
2
Back to 
