KLAYMAN v. OBAMA et al

Filing 75

STIPULATION of Dismissal by LOWELL C. MCADAMS, VERIZON COMMUNICATIONS. (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
similarly situated,
Plaintiffs,
No. 1:13-cv-00851-RJL

v.
BARACK HUSSEIN OBAMA,
ERIC HIMPTON HOLDER, JR.,
KEITH B. ALEXANDER, LOWELL C.
MCADAM, ROGER VINSON,
VERIZON COMMUNICATIONS,
NATIONAL SECURITY AGENCY, and
U.S. DEPARTMENT OF JUSTICE,
Defendants.

STIPULATION OF DISMISSAL
Pursuant to Federal Rule of Civil Procedure 41(a)(1)(ii), all parties that have appeared in
this action jointly stipulate to the voluntary dismissal without prejudice of any and all claims by
Plaintiffs against Defendants Verizon Communications Inc. and Lowell C. McAdam. All parties
shall bear their own costs.
Respectfully submitted,
/s/ Larry Klayman (as authorized)
Larry Klayman, Esq. (D.C. Bar No. 334581)
Freedom Watch, Inc.
2020 Pennsylvania Ave. NW, Suite 800
Washington, DC 20006
Tel: [phone]
[e-mail]

/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.: [phone]
Fax: [phone]
[e-mail]

Counsel for Plaintiffs

Counsel for the Verizon Defendants

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Stuart F. Delery
Assistant Attorney General
Joseph H. Hunt
Director, Federal Programs Branch
Anthony J. Coppolino
Deputy Branch Director
/s/ James J. Gilligan (as authorized)
James J. Gilligan
Special Litigation Counsel
Marcia Berman
Senior Trial Counsel
Bryan Dearinger
Rodney Patton
Trial Attorneys
U.S. Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Ave., N.W., Room 6102
Washington, D.C. 20001
Phone: [phone]
Fax: [phone]
Counsel for the Government Defendants

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CERTIFICATE OF SERVICE
I hereby certify that on January 31, 2014, 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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