KLAYMAN v. OBAMA et al

Filing 86

NOTICE Praecipe by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE (Attachments: # 1 Exhibit 1 -- Reply filed by the Government Defendants)(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' PRAECIPE
Plaintiffs Larry Klayman, Charles and Mary Ann Strange, Matt Garrison, and Michael
Ferrari, hereby file the attached pleading (Exhibit 1) with the Court, showing, as predicted, that
the Obama Justice Department is doing everything it can to slow down its appeal before the U.S.
Court of Appeals for the District of Columbia Circuit. Specifically, they come up with an
unsubstantiated -- if not bogus -- claim that because President Barack Obama gave a speech
offering to modify the NSA surveillance programs that the appeals should somehow be delayed
two months from February 27, 2014 to April 28, 2014 with regard to the deadline to file their
dispositive motions.
As Plaintiffs have represented to this Court, and as this Court itself has observed, these
obvious delay tactics come as no surprise. In effect, the Obama Justice Department and the
Defendants are flouting the Court's admonition in its order of December 16, 2013 which directed
the Defendants to move their appeal quickly, given the Court's gracious stay of its order.

Dated: February 25, 2014
Respectfully submitted,

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/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 25th day of February, 2014 a true and correct copy of the
foregoing Plaintiffs' Praecipe (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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