KLAYMAN v. OBAMA et al

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)

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.

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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: [phone]
Email: [e-mail]

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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
[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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