KLAYMAN v. OBAMA et al
Memorandum in opposition to re 40 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
BARACK HUSSEIN OBAMA,
ERIC HIMPTON HOLDER, JR.,
KEITH B. ALEXANDER, LOWELL C.
MCADAM, ROGER VINSON,
NATIONAL SECURITY AGENCY, and
U.S. DEPARTMENT OF JUSTICE,
VERIZON DEFENDANTS’ OPPOSITION TO PLAINTIFFS’
FOURTH MOTION FOR EXTENSION OF TIME TO CERTIFY CLASS ACTION
The Verizon defendants1 respectfully oppose Plaintiffs’ fourth Motion for Extension of
Time To Certify Class Action (Dkt. No. 40) for the same reasons Verizon opposed Plaintiffs’
initial motion for an extension. See Verizon Communications Inc.’s Opp’n to Pls.’ Mot. for
Extension of Time To Certify Class Action (Dkt. No. 11).
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.
Dated: November 30, 2013
/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.: (202) 663-6000
Fax: (202) 663-6363
Counsel for the Verizon Defendants
CERTIFICATE OF SERVICE
I hereby certify that on November 30, 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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