Filing 19

MOTION to Continue Status Conference Concerning Preliminary Injunction by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE (Attachments: # 1 Text of Proposed Order)(Klayman, Larry)

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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 MOTION FOR CONTINUANCE OF AND TO RESET STATUS CONFERENCE CONCERNING PRELIMINARY INJUNCTION MOTION Plaintiffs, Larry Klayman, and Charles and Mary Ann Strange, hereby request that this Court Continue the Status Conference of October 31, 2013 to November 4th or 5th, 2013 and as grounds therefor would show: 1. On October 29, 2013 this Court set a Status Conference to be held on October 31, 2013 at 3:45 pm in courtroom 18. 2. Mr. Klayman is currently located in Los Angeles, CA and has a pre-booked schedule there this week, but is scheduled to return to Washington, D.C. over the weekend. 3. Due to the short amount of time before the scheduled Status Conference, and because of pre-existing obligations in Los Angeles, Mr. Klayman cannot at this time travel to Washington, D.C. in time for the Status Conference currently scheduled for October 31, 2013. 4. Plaintiffs previously requested to have their counsel appear telephonically and this Court denied the motion. 1 5. A short continuance until Monday or Tuesday, November 4th or 5th, respectfully, will allow Mr. Klayman to travel back to Washington, D.C. and attend the Status Conference. 6. Mr. Klayman's associate spoke with Mr. Sloan from this Court's chambers who indicated that a motion for continuance could be filed and granted if Mr. Klayman could not make it to the Status Conference. 7. Plaintiffs contacted Defendants' counsel to seek consent for this motion but has not heard back from Defendants at the time of this filing. 8. Neither party will be prejudiced as a result of this short continuance. WHEREFORE, Plaintiffs respectfully request that this Court continue the Status Conference currently set for October 31, 2013 to November 4th or 5th, 2013. Dated: October 30, 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: (310) 595-0800 Email: leklayman@gmail.com 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 30th day of October, 2012 a true and correct copy of the foregoing Motion for Continuance (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 (202) 616-4169 Fax: 202-616-4314 Email: james.whitman@usdoj.gov James J. Gilligan Special Litigation Counsel Civil Division, Federal Programs Branch U.S. Department of Justice P.O. Box 883 Washington, D.C. 20044 (202) 514-3358 Email: James.Gilligan@usdoj.gov Randolph D. Moss WILMER CUTLER PICKERING HALE & DORR LLP 1875 Pennsylvania Avenue, NW Washington, DC 20006 (202) 663-6640 Fax: (202) 663-6363 Email: randolph.moss@wilmerhale.com 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: (310) 595-0800 3

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