KLAYMAN v. OBAMA et al

Filing 58

ERRATA Substituting Corrected Version of Exhibit D by U.S. DEPARTMENT OF JUSTICE 52 MOTION to Dismiss or, in the Alternative for Summary Judgment, Regarding Plaintiffs' Claims Against the Verizon Defendants MOTION for Summary Judgment filed by U.S. DEPARTMENT OF JUSTICE. (Attachments: # 1 Exhibit)(Patton, Rodney)

UNITED STATES DISTRICT COURT
DISTRICT OF COLUMBIA
____________________________________
)
LARRY KLAYMAN, et al.
)
)
Plaintiffs,
)
)
Civil Action No. 13-cv-0851 (RJL)
v.
)
)
BARACK OBAMA, President of the
)
United States, et al.
)
)
Defendants.
)
____________________________________)
ERRATA
Defendant United States Department of Justice respectfully submits this Errata in order to
substitute the attached Exhibit D for the version of that exhibit filed on December 16 with the
DOJ’s Motion to Dismiss Claims Against the Verizon Defendants, or in the Alternative for
Summary Judgment, Submitted by Defendant United States Department of Justice Pursuant to
Section 802 of the Foreign Intelligence Surveillance Act, 50 U.S.C. § 1885a(a). (ECF No. 52).
Exhibit D is the Public Declaration of Frances J. Fleisch, Acting Deputy Director of the National
Security Agency.
The version of Exhibit D sent via electronic mail to the parties and also to the Court at
[e-mail], while the Court’s ECF system was experiencing problems,
contained the appropriate text. When the ECF system came back online hours later, counsel for
the Defendant Department of Justice attached the same version of the document as Exhibit D
when filing on the ECF system the above-referenced motion. The exhibit now appears blank
when downloaded from the Court’s ECF system, however. This Errata corrects that error.
Counsel regrets any inconvenience caused by this error.

Dated: December 17, 2013
Respectfully submitted,
STUART F. DELERY
Assistant Attorney General
JOSEPH H. HUNT
Director, Federal Programs Branch
ANTHONY J. COPPOLINO
Deputy Branch Director
/s/ Rodney Patton
JAMES J. GILLIGAN
Special Litigation Counsel
MARCY BERMAN
Senior Trial Counsel
BRYAN DEARINGER
RODNEY PATTON
Trial Attorneys
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, N.W., Rm. 7320
Washington, D.C. 20530
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for the Government Defendants