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)

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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 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. 1 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 2 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 3

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