KLAYMAN v. OBAMA et al

Filing 62

MOTION for Extension of Time to File Response/Reply as to 55 MOTION to Dismiss Plaintiffs' Second Amended Complaint, 52 MOTION to Dismiss or, in the Alternative for Summary Judgment, Regarding Plaintiffs' Claims Against the Verizon Defendants MOTION for Summary Judgment by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE (Attachments: # 1 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

PLAINTIFFS' MOTION FOR EXTENSION OF TIME

Plaintiffs hereby move for an extension of fourteen (14) days to file an opposition to the
Defendants' motion to dismiss and as grounds therefor would show:

1. On December 16, 2013 the government Defendants and the Verizon Defendants filed
their respective motions to dismiss in the above styled lawsuit.
2. The response for both motions to dismiss are currently set for January 2, 2013, the day
after the New Years holiday.
3. During this holiday period Plaintiff Klayman's office is short staffed. In addition to the
already shortened resources, one of Plaintiff's colleagues has been ill and the office has
been inundated with the press of business during the time in which the oppositions to the
Defendants' motions would be due.
4. A short extension of two weeks would enable Plaintiff Klayman's office to return to full
strength and allow them the opportunity to fully research and brief an opposition to the
Defendants' motions.

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5. Pursuant to Local Rule 7(m), the Plaintiffs conferred with counsel for the Defendants
regarding the relief they seek in this motion. The government Defendants have
indicated that they consent to this motion. The Verizon Defendants have indicated
that they do not object to this motion.

WHEREFORE, Plaintiffs respectfully requests an extension of fourteen days or until
January 16, 2013 to file a response to Defendants' motion to dismiss.

Dated: December 24, 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 24th day of December a true and correct copy of the foregoing
Plaintiffs' Motion for Extension of Time (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]
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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