KLAYMAN v. OBAMA et al

Filing 89

REPLY to opposition to motion re 79 MOTION to Supplement the Record filed by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE. (Klayman, Larry)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
LARRY KLAYMAN, et. al
Plaintiffs,
v.
BARACK HUSSEIN OBAMA II, et. al

Defendants.

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

PLAINTIFFS REPLY TO GOVERNMENT DEFENDANTS’ OPPOSITION TO
PLAINTIFFS’ MOTIONS FOR LEAVE TO FILE SURREPLIES TO GOVERNMENT
DEFENDANTS’ REPLY IN SUPPORT OF PARTIAL MOTION TO DISMISS; AND
PLAINTIFFS REPLY TO GOVERNMENT DEFENDANTS OPPOSITION TO
PLAINTIFFS’ MOTION TO SUPPLEMENT THE RECORD
The Government Defendants reply seeks to elevate form over substance because
Plaintiffs’ factual and legal arguments are well taken. Accordingly, Plaintiffs respectfully request
that the Court consider their surreply.

Dated: March 4, 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]

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 4th day of March, 2014 a true and correct copy of the
foregoing Plaintiffs' Plaintiffs Reply To Government Defendants’ Opposition To Plaintiffs’
Motions For Leave To File Surreplies To Government Defendants’ Reply In Support Of Partial
Motion To Dismiss; And Plaintiffs Reply To Government Defendants Opposition To Plaintiffs’
Motion To Supplement The Record (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
2020 Pennsylvania Ave. NW, Suite 800
Washington, DC 20006
Tel: [phone]