KLAYMAN v. OBAMA et al

Filing 13

MOTION for Preliminary Injunction by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1 -- Affidavit of Larry Klayman, # 3 Exhibit 2 -- Affidavit of Charles Strange, # 4 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

Defendants.

Civil Action No. 13-CV-851

PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION
Pursuant to Fed. R. Civ. P. 65 and LCvR 65.1, the above named Plaintiffs hereby move
for a preliminary injunction that, during the pendency of this suit, (i) bars Defendants from
collecting Plaintiffs’ call records under the mass call surveillance program; (ii) requires
Defendants to destroy all of Plaintiffs’ call records already collected under the program; and (iii)
prohibits Defendants from querying metadata obtained through the program using any phone
number or other identifier associated with Plaintiffs for the reasons set forth in the accompanying
memorandum of law, and such other relief as may be found just and proper, as set forth in the
accompanying Plaintiffs' Memorandum of Points and Authorities.
Plaintiffs’ counsel conferred with Defendants’ counsel on October 24, 2013, concerning
this motion. Defendants' counsel indicated that they oppose this motion.

Dated: October 28, 2013
Respectfully submitted,

/s/ Larry Klayman
Larry Klayman, Esq.
Attorney at Law

D.C. Bar No. 334581
2020 Pennsylvania Ave. NW, Suite 800
Washington, DC 20006
Tel: [phone]
Email: [e-mail]

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 28th day of October, 2013 a true and correct copy of the
foregoing Motion for Preliminary Injunction (Civil Action No. 13-cv- 851) was submitted
electronically to the District Court for the District of Columbia and served via CM/ECF upon the
following:
James R. Whitman
U.S. DEPARTMENT OF JUSTICE
P.O. Box 7146
Washington, DC 20044
[phone]
Fax: [phone]
Email: [e-mail]
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]
Randolph D. Moss
WILMER CUTLER PICKERING HALE & DORR LLP
1875 Pennsylvania Avenue, NW
Washington, DC 20006
[phone]
Fax: [phone]
Email: [e-mail]
Attorney for Defendants.
Respectfully submitted,
/s/ Larry Klayman
Larry Klayman, Esq.
D.C. Bar No. 334581
Klayman Law Firm
2020 Pennsylvania Ave. NW, Suite 345
Washington, DC 20006
Tel: [phone]
Email: [e-mail]