KLAYMAN v. OBAMA et al

Filing 20

Memorandum in opposition to re 14 MOTION for Extension of Time to Certify Class Action filed by LOWELL C. MCADAMS, VERIZON COMMUNICATIONS. (Attachments: # 1 Text of Proposed Order)(Boynton, Brian)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LARRY E. KLAYMAN, CHARLES
STRANGE, and MARY ANNE STRANGE,
on behalf of themselves and all others
similarly situated,
Plaintiffs,
No. 1:13-cv-00851-RJL
v.
BARACK HUSSEIN OBAMA,
ERIC HIMPTON HOLDER, JR.,
KEITH B. ALEXANDER, LOWELL C.
MCADAM, ROGER VINSON,
VERIZON COMMUNICATIONS,
NATIONAL SECURITY AGENCY, and
U.S. DEPARTMENT OF JUSTICE,
Defendants.

VERIZON DEFENDANTS’ OPPOSITION TO PLAINTIFFS’
SECOND MOTION FOR EXTENSION OF TIME TO CERTIFY CLASS ACTION
The Verizon defendants1 respectfully oppose Plaintiffs’ second Motion for Extension of
Time To Certify Class Action (Dkt. No. 14) for the same reasons Verizon opposed Plaintiffs’
initial motion for an extension, which is still pending. See Verizon Communications Inc.’s
Opp’n to Pls.’ Mot. for Extension of Time To Certify Class Action (Dkt. No. 11).

1

There is no personal jurisdiction over the Verizon defendants in this district. The Verizon
defendants therefore reserve the right to challenge personal jurisdiction in their response to
Plaintiffs’ amended complaint. The Verizon defendants do not, by opposing Plaintiffs’
procedural motion, concede personal jurisdiction.
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Dated: October 31, 2013

Respectfully submitted,
/s/ Brian M. Boynton
Randolph D. Moss (D.C. Bar No. 417749)
Brian M. Boynton (D.C. Bar. No. 483187)
WILMER CUTLER PICKERING HALE AND DORR LLP
1875 Pennsylvania Avenue, NW
Washington, DC 20006
Tel.: [phone]
Fax: [phone]
[e-mail]
Counsel for the Verizon Defendants

2

CERTIFICATE OF SERVICE
I hereby certify that on October 31, 2013, I filed the foregoing document with the Clerk
of Court for the United States District Court for the District of Columbia using the Court’s
CM/ECF system, which caused notice of the filing to be served upon all counsel of record.

/s/ Brian M. Boynton
Brian M. Boynton

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