KLAYMAN v. OBAMA et al

Filing 14

MOTION for Extension of Time to Certify Class Action by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE (Attachments: # 1 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 RJL
Defendants.

MOTION FOR EXTENSION OF TIME TO CERTIFY CLASS ACTION

Plaintiffs hereby move this court for an extension of time of ten (10) days to file a motion
moving for class certification in the above styled lawsuit and as grounds therefor would show:
1. Plaintiffs filed suit challenging on Constitutional grounds the legality of Defendants’
participation and conduct in a secret and illicit government scheme to intercept and
analyze vast quantities of domestic telephonic communications.
2. Plaintiffs have been engaged in a heavy period of litigation. Due to the press of business,
and the large amount of work that went into preparing the Plaintiffs' Motion for
Preliminary Injunction (filed on the previous day to this motion), the Plaintiffs have been
unable to fully research draft a motion for class certification.
3. In addition, every day new information is coming to light that shows, among other things,
how the National Security Agency has been lying to this Court and the American public
about what information is being gathered and monitored and the extent to which the
American people are being spied upon by their own government.

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4. Because of all the uncertainty and the new information that has come to light the
Plaintiffs are still in the process of determining the different defined classes that will be
part of this lawsuit.
5. A short extension of ten days will allow the Plaintiff to gather the information needed to
prepare and file a motion to certify this lawsuit as a class action.
6. No prejudice will result to the Defendants, as they have yet to file responsive pleadings.
7. Defendants have not granted consent to this motion.

WHEREFORE, Plaintiffs respectfully move for an additional ten (10) days to move for
certification of a class action in the above styled lawsuit on or by November 12, 2013.

Dated: October 29, 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]

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 29th day of October, 2012 a true and correct copy of the
foregoing Motion for Extension of Time to Certify Class Action (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]
Attorneys 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]

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