KLAYMAN v. OBAMA et al

Filing 34

MOTION for Leave to File Supplemental Affidavit re 13 MOTION for Preliminary Injunction by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE (Attachments: # 1 Exhibit 1 -- Affidavit of David Siler, # 2 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 LEAVE TO FILE SUPPLEMENTAL AFFIDAVIT

Plaintiffs hereby move this Court for leave to file the supplemental affidavit of David
Siler (Attached as Exhibit 1) and as grounds therefor would show
1. On October 28, 2013 the Plaintiffs filed a Motion for Preliminary Injunction in the above
styled lawsuit.
2. This Court has set a hearing on the Motion for Preliminary Injunction on November 18,
2013.
3. New information has come to light within the past few hours from a computer expert,
David Siler, that corroborates the previous affidavit of Charles Strange, which was filed
in conjunction with the Motion for Preliminary Injunction, that the NSA and the
government are spying on the Plaintiff and violating the Patriot Act, the Foreign
Intelligence Surveillance Act, and the U.S. Constitution.
4. Mr. Siler has created an affidavit and the Plaintiffs have attached the Affidavit of Mr.
Siler as Exhibit 1.

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5. Mr. Siler’s affidavit will aid the Court and provide further evidence to the Court that a
preliminary injunction is warranted in this lawsuit.
6. Neither party will be prejudiced as a result of the filing of this affidavit.
7. The Plaintiffs contacted Defendants’ counsel to seek consent for this motion. The
Defendants’ counsel have not indicated whether they consent to this motion as of the time
of this filing, which is being made in anticipation of the hearing on November 18, 2013.

WHEREFORE, the Plaintiffs respectfully request that this Court grant leave to the
Plaintiffs to file the supplemental affidavit of David Siler, which is attached as Exhibit 1.

Dated: November 18, 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 1st day of November 17, 2013 a true and correct copy of the
foregoing Motion For Leave To File Supplemental Affidavit (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 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]
James R. Whitman
U.S. DEPARTMENT OF JUSTICE
P.O. Box 7146
Washington, DC 20044
[phone]
Fax: [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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