KLAYMAN v. OBAMA et al

Filing 102

MOTION for Telephonic Status Conference by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE (Attachments: # 1 Exhibit 1 -- Associated Press article about Jimmy Carter, # 2 Exhibit 2 -- Transcript of President Obama's Remarks from March 25, 2014, # 3 Text of Proposed Order)(Klayman, Larry)

IN UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LARRY KLAYMAN, et. al.,
Plaintiffs,

v.

BARACK HUSSEIN OBAMA II, et. al.

Civil Action No.: 13-cv-851
13-cv-881

Defendants.
Judge Richard J. Leon

MOTION FOR TELEPHONIC STATUS CONFERENCE

Plaintiffs, Larry Klayman, Charles Strange, Mary Ann Strange, Matt Garrison, and
Michael Ferrari, respectfully request, at the Court's convenience, a telephonic status conference.
It is apparent that the Government and Individual Government Defendants are having an
increasingly chilling effect on the communications of American citizens who have no connection
to terrorism, including former presidents who no longer use the phone or internet because they
too are in fear of their current government. (See Exhibit 1 -- Associated Press article about
President Carter refusing to Communicate by phone or internet). In the face of this, Defendant
Obama, just yesterday, at a press conference in the Netherlands, disingenuously told American
citizens and the world that "I’m confident that everybody in our intelligence agencies operates in
the best of intentions and is not snooping into the privacy of ordinary Dutch, German, French or
American citizens." See Exhibit 2 -- Transcript of President Obama's Remarks from March 25,
2014. Obviously, this has proven false, as the Court ruled on December 16, 2013. See Mem.

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Opinion of December 16, 2013. Thus, the illegal and unconstitutional conduct is not only
ongoing, but the Government continues to lie about its actions.
Plaintiffs thank the Court for its consideration.
Plaintiffs contacted Defendant's counsel to seek consent for this motion. Predictably,
Counsel for Defendants stated that they do not see the need for a status conference at this time.

Dated: March 26, 2014
Respectfully submitted,

/s/ Larry Klayman
Larry Klayman, Esq.
General Counsel
Freedom Watch, Inc.
D.C. Bar No. 334581
2020 Pennsylvania Ave. NW, Suite 345
Washington, DC 20006
Tel: [phone]
Email: [e-mail]
Attorney for Plaintiffs and the Class

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 26th day of March, 2014, a true and correct copy of
the foregoing Motion For Telephonic Status Conference (Civil Action No. 13-cv-851 and 13-cv881) was submitted electronically to the District Court for the District of Columbia and served
via CM/ECF upon the following:

James J. Gilligan
Special Litigation Counsel
Civil Division, Federal Programs Branch
U.S. Department of Justice
P.O. Box 883
Washington, D.C. 20044
[phone]
Email: [e-mail]

Attorneys for Defendants.

Respectfully submitted,
/s/ Larry Klayman
Larry Klayman, Esq.
General Counsel
Freedom Watch, Inc.
D.C. Bar No. 334581
2020 Pennsylvania Ave. NW, Suite 345
Washington, DC 20006
Tel: [phone]
Email: [e-mail]

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