KLAYMAN v. OBAMA et al

Filing 72

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
Civil Action Nos. 13-cv-851
and
13-cv-881

Defendants.

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. Plaintiffs previously moved this Court for an extension until January 16, 2014 to respond
to the Defendants' motions.
3. On January 10, 2014 the government Defendants moved to stay these proceedings
pending the appeal.
4. Counsel for Plaintiffs had to use considerable time recently to prepare an opposition to
the government NSA Defendants motion to stay. Opposition to this motion is crucial to
expeditiously move this case into the discovery phase and ultimately to trial, as
constitutional rights continue to be violated. He has also had to address some urgent
matters in other cases, and thus needs addition time to respond to the subject motions to
dismiss.

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5. A short extension of fourteen (14) days would enable Plaintiffs to fully research and brief
an opposition to the Defendants' motions.
6. 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
consent to this motion.
WHEREFORE, Plaintiffs respectfully requests an extension of fourteen days or until
January 30, 2014 to file a response to Defendants' motion to dismiss.

Dated: January 16, 2014
Respectfully submitted,
/s/ Larry Klayman
Larry Klayman, Esq.
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 16th day of January a true and correct copy of the foregoing
Plaintiffs' Motion for Extension of Time (Civil Action Nos. 13-cv- 851 and 13-cv-881) 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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