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 Nos. 13-cv-851
13-cv-881

AFFIDAVIT OF CHARLES STRANGE
1.

My name is Charles Strange, I am over 18 years old. I am an adult citizen of the United

States and I am the Plaintiff in the above styled case. I have personal knowledge of the facts
stated in this declaration.
2.

I have been a subscriber and user of Verizon Wireless for my cellular phone service for

many years and have been a subscriber and user of Verizon Wireless at all material times.
3.

I am also a user of internet services by Apple, Microsoft, YouTube, Yahoo, Google,

Facebook, AT&T, and Skype and have been users of these services at all material times.
4.

I routinely communicate with my attorneys and members of the public, as well as

journalists and associates by telephonic communications and electronic messages through
Facebook, Google, Apple, and Skype.
5.

I am the father of Michael Strange, a cryptologist technician for the National Security

Agency ("NSA") and support personnel for Navy SEAL Team VI. My son, Michael, was killed
when the helicopter he was in was attacked and shot down by terrorist Taliban jihadists in
Afghanistan on August 6, 2011.

Page 1

6.

Michael was assigned to Navy SEAL Team VI, was a Petty Officer, and 1st Class

(Expeditionary Warfare Specialist) in the U.S. Navy.
7.

Because of Michael's position with the National Security Agency, he had access to

confidential NSA and military codes and other classified information. Michael knew how the
NSA worked and its methods of data collection and surveillance.
8.

I believe and have said publically that Michael's death was either negligently or

purposely caused by the U.S. government and/or the government of Afghanistan headed by its
corrupt President, Hamid Karzai.
9.

My wife Mary Ann, also a plaintiff, and I have been vocal about our criticism of

President Barack Obama as Commander-in-Chief, his administration, and the U.S. military
regarding the circumstances surrounding the shoot down of my son’s helicopter in Afghanistan,
which resulted in the death of my son, four other SEAL Team VI support personnel, seventeen
SEALs, five National Guardsmen, and three Air Force members. The fatal mission was code
named Extortion 17.
10.

My wife and I have substantial connections with Washington, D.C., as we hold press

conferences in Washington, D.C. and lobby in Washington, D.C. as advocates for my son as we
seek to obtain justice for him, as well as to change the policies and orders of President Obama
and the U.S. military’s acts and practices, which I believe contributed to my son’s death.
11.

Defendants’ mass call-tracking surveillance program has directly and significantly

impacted my wife and my abilities to communicate via telephone, email, and otherwise, given
the concern that confidential and private communications will be overheard, obtained by the
NSA’s surveillance program, and used against me and my family's interests.

Page 2

12.

Since the beginning of my advocacy and pursuit of justice for my son Michael, I have

experienced several instances in which I have experienced technological abnormal intrusions.
13.

On one occasion, I received an email that I believed was from Michael. It turned out that

the email was a hoax. I have reason to believe, based on the totality and continuing pattern of
circumstances set forth herein, that the NSA and Defendants were behind it as my son Michael
could not have sent it. He is dead. This intended to cause me harm, and indeed caused me severe
emotional distress. Exhibit 1.
14.

There have been times when I have received text messages from friends and relatives

who have told me that they had never sent the messages.
15.

Various other contacts of mine have received text messages that seemingly appear to

have been sent from my phone number, even though I had never sent said messages.
16.

Since my son's death, I have received numerous text messages from indiscriminate

numbers, all with one, two, three, four, or five digits. I called Verizon various times and its
employees stated that there is no record of the text messages being received or sent. Exhibit 2.
17.

In July of 2013, my wife was on the computer when it abruptly photographed her face

(through some form of abusive surveillance as my computer does not have a built-in camera),
and falsely accused my wife of violating "Copyright and Related Rights Law". Without a built-in
camera, a computer user cannot take a picture of him or herself. I have reason to believe that the
NSA and other Defendants were behind this as well. Exhibit 3.
18.

The secret surveillance that the government is performing on my wife and me is making

me afraid to communicate with my family, friends, and other contacts. I am in fear of my safety,
my family's safety, immediate bodily injury, and even death of myself, my family, and friends.

Page 3

This has heightened my emotional distress and I feel I am on the verge of a nervous breakdown.
I am currently undergoing psychological counseling as a result.
19.

I no longer feel able to speak as freely as I wish on the phone, or through text message

and email. I have been unable to speak freely with friends, family, and other contacts, whether
on the phone, through texts messages, or via email.
20.

These activities by the government are prohibiting my ability to associate, to lobby

Congress, to be politically active, and to communicate with my attorney Larry Klayman and
others at Freedom Watch. These activities are specifically diminishing my freedom of speech.

Sworn under penalty of perjury

Dated: October 28, 2013

/s/ Charles Strange
Charles Strange

Page 4

Exhibit 1

Exhibit 2

Exhibit 3