Page 1 PageID#
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
No. 1:23-cv-00108-LMB-JFA
vs.
GOOGLE LLC,
Defendant.
GOOGLE LLC’S EMERGENCY MOTION FOR CONTINUANCE
Pursuant to Rule 7(G) of the Local Civil Rules for the United States District Court,
Eastern District of Virginia, Defendant Google LLC (“Google”) moves for an order continuing
the September 8, 2023, Hearing on the Plaintiffs’ Motion for Judgment on the Pleadings or to
Strike as to Google's Tenth and Thirteenth Affirmative Defenses, or in the Alternative for a
Protective Order (ECF No. 317), by one week to September 15, 2023, because Google’s
counsel set to argue the motion tested positive for COVID-19 yesterday evening.
Local Civil Rule 7(G) provides, in pertinent part, that continuances may be granted “for
good cause and upon such terms as the Court may impose.” E.D. Va. Civ. R. 7(G). Here,
Google’s co-lead counsel, Eric Mahr, has tested positive for the COVID-19 and is currently
symptomatic. There are a number of depositions also taking place on September 8, including
one being taken by Google’s other co-lead counsel.
Google accordingly requests a brief, one-week continuance of the Hearing date to
September 15, 2022. Continuing the Hearing to that date will ensure that the Centers for
Disease Control and Prevention’s current isolation guidelines will be followed, thereby
protecting the health and safety of all who will be in attendance at the hearing, and allow
counsel adequate time to recover. See Order, Su v. JAG Contractors, Inc. et al, 1:22-cv-00783-Page 2 PageID#
LMB-WEF (E.D. Va. July 27, 2022), ECF No. 16 (granting motion to continue hearing for one
week where party’s counsel tested positive for COVID-19). To the extent certain depositions
may be affected by the Court’s ruling, none are currently scheduled during the intervening
week and therefore will not be delayed by the Court granting Google’s requested continuance.
Google has consulted with the Plaintiffs through counsel for the United States, and Plaintiffs
take no position on Google’s motion for a continuance.
For the foregoing reasons, Google respectfully submits that there exists good cause to
continue the Hearing for one week due to the COVID-19 diagnosis and ensuing illness of
counsel, and to safeguard the health and safety of the Court and all hearing attendees. A
proposed order is submitted herewith.
The parties do not seek oral argument on this continuance motion. Page 3 PageID#
Dated: September 6,
Respectfully submitted,
/s/ Craig C. Reilly
Craig C. Reilly (VSB # 20942)
THE LAW OFFICE OF
CRAIG C. REILLY, ESQ.
209 Madison Street
Alexandria, VA Telephone: (703) 549-Facsimile: (703) 549-craig.reilly@ccreillylaw.com
Eric Mahr (pro hac vice)
Andrew Ewalt (pro hac vice)
Julie Elmer (pro hac vice)
Lauren Kaplin (pro hac vice)
Scott A. Eisman (pro hac vice)
Jeanette Bayoumi (pro hac vice)
Claire Leonard (pro hac vice)
Sara Salem (pro hac vice)
Tyler Garrett (VSB # 94759)
FRESHFIELDS BRUCKHAUS
DERINGER US LLP
700 13th Street, NW, 10th Floor
Washington, DC Telephone: (202) 777-Facsimile: (202) 777-eric.mahr@freshfields.com
Counsel for Defendant Google LLC
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:23-cv-00108-LMB-JFA Document 395 Filed 09/06/23 Page 1 of 3 PageID# 5987
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES, et al.,
Plaintiffs,
No. 1:23-cv-00108-LMB-JFA
vs.
GOOGLE LLC,
Defendant.
GOOGLE LLC’S EMERGENCY MOTION FOR CONTINUANCE
Pursuant to Rule 7(G) of the Local Civil Rules for the United States District Court,
Eastern District of Virginia, Defendant Google LLC (“Google”) moves for an order continuing
the September 8, 2023, Hearing on the Plaintiffs’ Motion for Judgment on the Pleadings or to
Strike as to Google's Tenth and Thirteenth Affirmative Defenses, or in the Alternative for a
Protective Order (ECF No. 317), by one week to September 15, 2023, because Google’s
counsel set to argue the motion tested positive for COVID-19 yesterday evening.
Local Civil Rule 7(G) provides, in pertinent part, that continuances may be granted “for
good cause and upon such terms as the Court may impose.” E.D. Va. Civ. R. 7(G). Here,
Google’s co-lead counsel, Eric Mahr, has tested positive for the COVID-19 and is currently
symptomatic. There are a number of depositions also taking place on September 8, including
one being taken by Google’s other co-lead counsel.
Google accordingly requests a brief, one-week continuance of the Hearing date to
September 15, 2022. Continuing the Hearing to that date will ensure that the Centers for
Disease Control and Prevention’s current isolation guidelines will be followed, thereby
protecting the health and safety of all who will be in attendance at the hearing, and allow
counsel adequate time to recover. See Order, Su v. JAG Contractors, Inc. et al, 1:22-cv-00783-
PDF Page 3
Case 1:23-cv-00108-LMB-JFA Document 395 Filed 09/06/23 Page 2 of 3 PageID# 5988
LMB-WEF (E.D. Va. July 27, 2022), ECF No. 16 (granting motion to continue hearing for one
week where party’s counsel tested positive for COVID-19). To the extent certain depositions
may be affected by the Court’s ruling, none are currently scheduled during the intervening
week and therefore will not be delayed by the Court granting Google’s requested continuance.
Google has consulted with the Plaintiffs through counsel for the United States, and Plaintiffs
take no position on Google’s motion for a continuance.
For the foregoing reasons, Google respectfully submits that there exists good cause to
continue the Hearing for one week due to the COVID-19 diagnosis and ensuing illness of
counsel, and to safeguard the health and safety of the Court and all hearing attendees. A
proposed order is submitted herewith.
The parties do not seek oral argument on this continuance motion.
2
PDF Page 4
Case 1:23-cv-00108-LMB-JFA Document 395 Filed 09/06/23 Page 3 of 3 PageID# 5989
Dated: September 6, 2023
Respectfully submitted,
/s/ Craig C. Reilly
Craig C. Reilly (VSB # 20942)
THE LAW OFFICE OF
CRAIG C. REILLY, ESQ.
209 Madison Street
Alexandria, VA 22314
Telephone: (703) 549-5354
Facsimile: (703) 549-5355
craig.reilly@ccreillylaw.com
Eric Mahr (pro hac vice)
Andrew Ewalt (pro hac vice)
Julie Elmer (pro hac vice)
Lauren Kaplin (pro hac vice)
Scott A. Eisman (pro hac vice)
Jeanette Bayoumi (pro hac vice)
Claire Leonard (pro hac vice)
Sara Salem (pro hac vice)
Tyler Garrett (VSB # 94759)
FRESHFIELDS BRUCKHAUS
DERINGER US LLP
700 13th Street, NW, 10th Floor
Washington, DC 20005
Telephone: (202) 777-4500
Facsimile: (202) 777-4555
eric.mahr@freshfields.com
Counsel for Defendant Google LLC
3
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