KLAYMAN v. OBAMA et al
Filing
27
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 and other matters related to the hearing of November 18, 2013,
the Plaintiffs have been unable to fully research draft a motion for class certification.
3. 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.
4. No prejudice will result to the Defendants, as they have yet to file responsive pleadings.
5. Defendants have not granted consent to this motion.
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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 26, 2013.
Dated: November 12, 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
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 12th day of November, 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
(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
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