KLAYMAN v. OBAMA et al

Filing 40

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 THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

LARRY KLAYMAN, et. al
Plaintiffs,
v.
BARACK HUSSEIN OBAMA II, et. al
Civil Action Nos. 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. On November 18, 2013 a hearing was held in the above styled lawsuit, during which this
Court granted the parties the opportunity to submit additional briefing related to the
preliminary injunction. This briefing is due on November 26, 2013, the same day during
which the Plaintiffs requested their motion to certify their class would be due
3. A short extension of 10 days will allow the Plaintiffs the opportunity to prepare the
motion to certify the classes in these proceedings.
4. No prejudice will result to the Defendants.
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 December 10, 2013.

Dated: November 25, 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 25th day of November, 2013 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 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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