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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HOMEADVISOR, INC., 

a corporation, 

Docket No. 9407 

d/b/a ANGI LEADS, 

d/b/a HOMEADVISOR POWERED 

BY ANGI. 

JOINT MOTION TO EXTEND THE TIME TO 

COMPLETE FACT DISCOVERY 

Counsel for Respondent HomeAdvisor, Inc. (“HomeAdvisor” or “Respondent”) and 

Complaint Counsel (collectively, the “Parties”) jointly move this Court under 16 C.F.R. § 4.3(b), 

to extend the time for the completion of fact discovery to allow for the completion of the deposition 

of HomeAdvisor. 

Complaint Counsel served a Notice of Deposition to HomeAdvisor pursuant to 16 C.F.R. 

§ 3.33(c)(1) (the “Notice”) on July 8, 2022. The Notice lists 14 separate topics for which 

HomeAdvisor must designate a witness(es) to testify (the “Topics”). HomeAdvisor served 

responses and objections to the Notice on August 5, 2022. For the remainder of the month of 

August, the Parties engaged in good faith negotiations regarding the scope of the Topics, and 

successfully resolved all disputes concerning the Topics as of August 31, 2022. HomeAdvisor 

anticipates designating multiple witnesses to cover the 12 Topics for which it agreed to provide 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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testimony. Under the Scheduling Order, fact discovery closes on September 6, 2022.* Thus, to 

provide the Parties with a reasonable time to schedule the deposition for each of the designees, and 

to prepare for the depositions, the Parties propose a two-week extension to the deadline to complete 

fact discovery to September 20, 2022, solely for purposes of completing the deposition of 

HomeAdvisor. All other fact discovery shall be completed by September 6, 2022. By joining this 

motion, the parties do not preclude or otherwise limit their rights to subsequently file any motion 

to compel. Although the parties reserve their rights to propose further adjustments to the prehearing schedule, HomeAdvisor and Complaint Counsel do not currently propose any further 

adjustments to the pre-hearing schedule. 

The Administrative Law Judge may extend deadlines for “good cause shown.” 16 C.F.R. 

§ 4.3(b). Good cause exists for the brief extension sought in this motion because (1) it will provide 

the Parties reasonable time to schedule the depositions of multiple witnesses designated to testify 

on behalf of HomeAdvisor; (2) it will provide HomeAdvisor reasonable time fulfill its obligation 

under to 16 C.F.R. § 3.33(c)(1) to prepare its designees on “matters known or reasonably available 

to” HomeAdvisor; and (3) none of the proposed extensions will delay the overall schedule or 

require a change to the hearing date. 

No party will suffer any undue prejudice from the brief extensions requested. Moreover, 

the limited extension will not delay other procedural deadlines or the hearing date set for 

November, 9, 2022. 

* The Scheduling Order sets September 6 as the “close of discovery, other than discovery 

permitted under Rule 3.24(a)(4), depositions of experts, and discovery for purposes of authenticity 

and admissibility of exhibits.” For brevity, the Parties herein refer to this as the close of “fact 

discovery.”

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For these reasons, the Parties respectfully request that the Court enter the attached proposed 

Order. 

Dated: September 6, 2022 

Respectfully Submitted, 

/s/ Jennifer J. Barrett 

QUINN EMANUEL URQUHART & SULLIVAN, LLP 

William A. Burck 

Dawn Yamane Hewett 

Kyra R. Simon 

1300 I Street NW, 9th Floor 

Washington, DC 20005 

(202) 538-8000 

williamburck@quinnemanuel.com 

dawnhewett@quinnemanuel.com 

kyrasimon@quinnemanuel.com 

Stephen R. Neuwirth 

Jennifer J. Barrett 

Kathryn Bonacorsi 

Neil T. Phillips 

George T. Phillips 

51 Madison Avenue, 22nd Floor 

New York, NY 10010 

(212) 849-7000 

stephenneuwirth@quinnemanuel.com 

jenniferbarrett@quinnemanuel.com 

kathrynbonacorsi@quinnemanuel.com 

neilphillips@quinnemanuel.com 

georgephillips@quinnemanuel.com 

Attorneys for Respondent HomeAdvisor, Inc. 

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/s/ Sophia H. Calderón 

Sophia H. Calderón 

Colin D. A. MacDonald 

Breena M. Roos 

M. Elizabeth Howe 

Katharine F. Barach 

Nadine S. Samter 

Federal Trade Commission, Northwest Region 

915 Second Ave., Suite 2896 

Seattle, WA 98174 

Tel.: (206) 220-4486 

scalderon@ftc.gov 

cmacdonald@ftc.gov 

broos@ftc.gov 

mhowe@ftc.gov 

kbarach@ftc.gov 

nsamter@ftc.gov 

Counsel Supporting the Complaint 

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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

HOMEADVISOR, INC., 

a corporation, 

d/b/a ANGI LEADS, 

PUBLIC 

Docket No. 9407 

d/b/a HOMEADVISOR 

BY ANGI. 

POWERED 

[PROPOSED] ORDER 

Having carefully considered Respondent’s and Complaint Counsel’s Joint Motion To 

Extend the Time to Complete Fact Discovery, it is hereby 

ORDERED, that the close of fact discovery is extended to September 20, 2022, solely for 

the purposes of allowing the completion of the deposition of HomeAdvisor. 

ORDERED: 

D. Michael Chappell 

Chief Administrative Law Judge 

Date: 
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CERTIFICATE OF SERVICE 

I hereby certify that on September 6, 2022, I filed the foregoing document electronically 

through the Office of the Secretary’s FTC E-filing system, which will send notification of such 

filing to: 

April Tabor 

Secretary Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-113 Washington, DC 20580 

electronicfilings@ftc.gov 

The Honorable D. Michael Chappell 

Chief Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Avenue, NW, Room H-110 

Washington, DC 20580 

I also certify that I caused a true and correct copy of the foregoing documents to be 

served via email upon the following: 

Sophia H. Calderón 

Colin D. A. MacDonald 

Breena M. Roos 

M. Elizabeth Howe 

Katharine F. Barach 

Nadine S. Samter 

Federal Trade Commission, Northwest Region 

915 Second Ave., Suite 2896 

Seattle, WA 98174 

Tel.: (206) 220-4486 

scalderon@ftc.gov 

cmacdonald@ftc.gov 

broos@ftc.gov 

mhowe@ftc.gov 

kbarach@ftc.gov 

nsamter@ftc.gov 

Counsel Supporting the Complaint 

Dated: September 6, 2022 By: /s/ George T. Phillips 

George T. Phillips 

Counsel for Respondent HomeAdvisor, Inc. 
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CERTIFICATE FOR ELECTRONIC FILING 

I certify that the electronic copy sent to the Secretary of the Commission is a true and 

correct copy of the paper original and that I possess a paper original of the signed document that 

is available for review by the parties and the adjudicator. 

Dated: September 6, 2022 By: /s/ George T. Phillips 

George T. Phillips 

Counsel for Respondent HomeAdvisor, Inc.