KLAYMAN v. OBAMA et al

Filing 99

SUPPLEMENTAL MEMORANDUM to re 85 MOTION For Entry Of Default And To Strike Government Defendants Answer To Plaintiffs Third Amended Complaint re 83 Answer to Amended Complaint, filed by LARRY E. KLAYMAN, CHARLES STRANGE, MARY ANN STRANGE. (Attachments: # 1 Exhibit 1 -- Return Receipt for the Honorable Roger VInson)(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
Civil Action No. 1:13-cv-00851
Defendants.

SUPPLEMENT TO MOTION FOR ENTRY OF DEFAULT AND TO STRIKE
GOVERNMENT DEFENDANTS’ ANSWER TO PLAINTIFFS’ THIRD AMENDED
COMPLAINT

Plaintiffs, Larry Klayman, Charles Strange, and Mary Ann Strange, hereby file this
Supplement to Plaintiff's Motion For Entry Of Default And To Strike Government Defendants’
Answer To Plaintiffs’ Third Amended Complaint.
On February 20, 2014 Plaintiffs filed their Motion For Entry Of Default And To Strike
Government Defendants’ Answer To Plaintiffs’ Third Amended Complaint. In this motion,
Plaintiffs included the signed return receipt from the Defendants demonstrating that service was
made on the Defendants by United States Parcel Service Certified Mail. All of the Defendants
had signed return receipts except for the Honorable Roger Vinson and Verizon
Communications.1
In their Opposition, Defendants made a point that there was no proof of service on the
Honorable Roger Vinson as there was no return receipt delivered to the Plaintiffs, even though a
1

Verizon Communications is no longer a party to this action.
1

certificate of the Certified Mail was furnished. However, Plaintiff has just located the return
receipt for the Honorable Roger Vinson, and has attached a copy of the return receipt as Exhibit
1 to this supplement.

Dated: March 20, 2014
Respectfully submitted,
/s/ Larry Klayman
Larry Klayman, Esq.
General Counsel
Freedom Watch, Inc.
D.C. Bar No. 334581
2020 Pennsylvania Ave. NW, Suite 345
Washington, DC 20006
Tel: [phone]
Email: [e-mail]
Attorney for Himself, Pro Se, and Plaintiffs

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 20th day of March, 2014, a true and correct copy of the
foregoing Supplement to Motion for Entry of Default And To Strike Government Defendants’
Answer To Plaintiffs’ Third Amended Complaint (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.
General Counsel
Freedom Watch, Inc.
D.C. Bar No. 334581
2020 Pennsylvania Ave. NW, Suite 345
Washington, DC 20006
Tel: [phone]
Email: [e-mail]

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