Case: Klayman v. Obama

1:13-cv-00881 | U.S. District Court for the District of District of Columbia

Filed Date: June 12, 2013

Closed Date: Feb. 5, 2019

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Case Summary

This is the first U.S. District Court to rule on the National Security Agency's ("NSA") so-called "Bulk Telephony Metadata Program" under Section 501 of the Foreign Intelligence Surveillance Act of 1978 ("FISA"), commonly referred to as Section 215 of the USA PATRIOT Act. Under the program, the NSA has apparently collected records from large telecommunication companies about virtually all domestic telephone calls. These records, termed "telephony metadata," include the phone numbers placed and received; the date, time and duration of calls; some location identifiers; and calling card numbers. The records, however, allegedly do not include the parties' names, addresses or financial information or the call's content.

On June 5, 2013, London's Guardian newspaper reported about the NSA's surveillance efforts based on a classified document leaked by former NSA contractor Edward Snowden. Following the leak, the U.S. government admitted that it has for a number of years collected, compiled, and analyzed telephony metadata, as business records, from certain telecommunication companies.

The following day, on June 6, 2013, individual subscribers of Verizon Wireless, filed a lawsuit in the U.S. District Court for the District of Columbia against the NSA, claiming that the NSA's program exceeded statutory authority under FISA and violated the First and Fourth Amendments. The plaintiffs, among other things, sought an injunction to stop the collection of their individual phone records and also an order requiring the disposal of any records previously collected about them.

On December 16, 2013, U.S. District Judge Richard Leon granted in part the plaintiffs' motion for a preliminary injunction. 957 F. Supp. 2d 43. While Judge Leon found that the plaintiffs lacked standing to proceed with their allegations that the NSA exceeded its authority under FISA, he said that this finding did not preclude consideration of the plaintiffs' constitutional claims. Therefore, he analyzed whether the NSA violated the plaintiffs' "reasonable expectation of privacy," protected by the Fourth Amendment, when it collected and queried their telephone metadata records, without probable cause or reasonable suspicion of wrongdoing.

Judge Leon held that the NSA's Bulk Telephony Metadata Program likely violates the Fourth Amendment to the Constitution, as an "indiscriminate and arbitrary" invasion of citizens' reasonable expectation of privacy. Judge Leon was troubled by a number of issues in the case, including the close and apparently unsupervised relationship between the NSA and telephone companies, as well as the apparent ineffectiveness of the program.

The court ruled that the Supreme Court precedent Smith v. Maryland, 442 U.S. 735 (1979), which established that phone metadata is not subject to the Fourth Amendment, was distinguishable. For Judge Leon, the 34-year-old precedent was distinguishable, given modern surveillance capabilities, the evolving role of phones and technologies in the digital age, namely cell phones, and the telecommunication companies' daily dump of bulk metadata records to government.

Although Judge Leon ruled in the plaintiffs' favor, he stayed his order to allow the government time to appeal, in light of the significant national security interests at stake and the novelty of the constitutional issues. The federal government appealed the district court's decision to the District of Columbia U.S. Court of Appeals on January 9, 2014.

Under a "sunset" clause, the relevant section of the U.S. Code amended by Section 215 was scheduled to revert to its pre-2001 form on June 1, 2015 unless Congress acted. See Pub.L. No. 109-177, § 102(b)(1), 120 Stat. 192, 194-95 (2006); Pub. L. No. 112-14, § 2(a), 125 Stat. 216, 216 (2011). That date came and went without any legislative action. One day after the deadline, however, Congress enacted the USA Freedom Act, which revived the language added by Section 215 with some substantial changes, eliminating the government's holding of the bulk telephony metadata and presumably mooting (or substantially altering) this case. See Pub. L. No. 114-23, Tit. I, 129 Stat. 268, 269-77 (2015), codified at 50 U.S.C. § 1861. The Act's changes do not take effect until 180 days after the date of enactment--November 29, 2015. Id. § 109(a), 129 Stat. at 276.

On August 28, 2015, the Court of Appeals reversed and remanded for further proceedings. There was no opinion for the court. The judgment was announced in a per curiam order, which explained why the case was not moot notwithstanding the significant statutory alterations ordered in June 2015--which had not yet taken effect. Judge Janice Rogers Brown wrote an opinion setting out her view that the plaintiffs had "barely" fulfilled the requirements for standing--and might be able to bolster that showing on remand. She did not agree with the district court, however, that a preliminary injunction was appropriate because the plaintiffs had not established a sufficient likelihood of prevailing in the case as a whole. Judge Stephen Williams emphasized that the government had acknowledged bulk collection from Verizon Business Network Services, whereas the plaintiffs were subscribers to Verizon Wireless. Accordingly, they lack direct evidence that information about their calls was ever collected--and therefore lacked standing. Judge David Sentelle dissented; he explained that would have dismissed the case outright.

The case accordingly continues in district court. Judge Leon explained that he interpreted the remand as asking him to determine whether limited discovery is appropriate to satisfy the standing requirements set forth in Clapper v. Amnesty Int'l, 133 S.Ct. 1138 (2013). On remand, on September 8, 2015, plaintiffs sought leave to file a Fourth Amended Complaint, adding additional plaintiffs who were subscribers to Verizon Business Network Services, not just Verizon Wireless. At a hearing on September 16, 2015, Judge Leon granted the motion (which was uncontested). A few days later, plaintiffs filed a renewed motion for preliminary injunction, seeking to enjoin the bulk telephony metadata program, which had not yet expired. A hearing was held on October 8, 2015. On November 9, 2015, Judge Leon decided that the new plaintiffs in the case had made a sufficient showing of standing, and were entitled to a preliminary injunction. The court granted an injunction against continued collection and querying of the telephone record metadata for the new plaintiffs, only. Even though the telephony metadata program was scheduled to expire and be replaced by a significantly different program later that month, the court declined to stay its order.

The government immediately sought a stay from the Court of Appeals, which in a per curiam order (Tatel, Griffith, Millett) granted a limited stay on November 10, 2015, "to consider the merits of the motion for a stay." The court required briefing on the stay motion to be completed by November 16, 2015. That day, the panel granted a stay; the D.C. Circuit denied rehearing on banc on November 20, 2015, with a concurrence by Judge Brett Kavanaugh staying his view that the metadata program was consistent with the Fourth Amendment.

On February 11, 2016, the plaintiffs filed their third amended complaint in which they reasserted their constitutional claims under the First, Fourth, and Fifth Amendments. The defendants responded on February 19, with a motion to quash service on the Director of the NSA and a motion to dismiss the individual federal defendants who were being sued while serving in their official capacities.

On May 30, Judge Leon filed an order to stay the case pending final disposition of the defendants’ appeal of the District Court’s preliminary injunction. Less than a week later, the plaintiffs filed a motion to lift the stay.

The stay was lifted on September 20, 2016. On that day, Judge Leon granted the defendants’ motion to quash and motion to dismiss the individual federal defendants; the complaint is now dismissed as to those parties.

On November 17, 2016, the defendants filed a motion to dismiss for lack of subject matter jurisdiction. One year later, on November 21, 2017, Judge Leon granted the defendants' dismissal. He combined this case with a similar case also filed by the plaintiffs in the district of DC (1:13-cv-00851). He granted the defendants' motion to dismiss and dismissed both cases with prejudice, explaining that plaintiffs' requests for declaratory and prospective injunctive relief are mooted by the USA FREEDOM Act, which prohibits bulk collection of metadata. The plaintiffs therefore no longer have a live Article III case of controversy.

On December 21, 2017, plaintiffs appealed Judge Leon's decision to the United States Court of Appeals for the District of Columbia Circuit (Docket #17-5282). On January 7, 2019, the Appeals Court (Circuit Judges Rogers, Srinivasan, and Pillard) concluded in a per curiam order, on its own motion, that oral argument would not be necessary and that it would dispose of the appeal on the basis of the record and the presentations in the briefs. On February 5, 2019, the appeals court affirmed the district court’s judgment, finding that the plaintiffs lacked standing because they only generally alleged that “they communicate with various individuals in countries [plaintiffs] imagine might attract government surveillance.” The case is now closed.

On March 2, 2019, Luke Murry, National Security Advisor to Republican House Minority Leader Kevin McCarthy, discussed the status of the USA FREEDOM Act during a podcast for the national security website Lawfare. Mr. Murry disclosed that the Trump administration “hasn’t actually been using it for the past six months,” and that the administration might not ask Congress to renew its legal authority, which is set to expire on December 15, 2019.

	Document
1:13-cv-00881	Docket [PACER]	Dec. 26, 2017	Dec. 26, 2017 Docket
1 1:13-cv-00881	Complaint	June 12, 2013	June 12, 2013 Complaint
25-4 1:13-cv-00851	Declaration of Teresa H. Shea, Signals Intelligence Director National Security Agency	Oct. 1, 2013	Oct. 1, 2013 Declaration/Affidavit
25-5 1:13-cv-00851	Declaration of Acting Assistant Director Robert J. Holley, FBI	Oct. 1, 2013	Oct. 1, 2013 Declaration/Affidavit
68-1 13-cv-03994	Supplemental Declaration of Professor Edward W. Felten	Oct. 25, 2013	Oct. 25, 2013 Declaration/Affidavit
26 1:13-cv-00881	Plaintiffs' Reply in Support of Their Motions for Preliminary Injunction	Nov. 14, 2013	Nov. 14, 2013 Pleading / Motion / Brief
31 1:13-cv-00881	Affidavit of David M. Siler	Nov. 17, 2013	Nov. 17, 2013 Declaration/Affidavit
29 1:13-cv-00881	Motion for Leave to File Supplemental Affidavit	Nov. 18, 2013	Nov. 18, 2013 Pleading / Motion / Brief
30 1:13-cv-00881	Amended Complaint	Nov. 23, 2013	Nov. 23, 2013 Complaint
55 1:13-cv-00851	Defendants' Motion to Dismiss Plaintiffs' Second Amended Complaint	Dec. 16, 2013	Dec. 16, 2013 Pleading / Motion / Brief

ECF Number	Description	Date	Link Date / Link
1	COMPLAINT against All Plaintiffs with Jury Demand ( Filing fee $ 400 receipt number 0090-3357864) filed by LARRY E. KLAYMAN. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet)(Klayman, Larry) (Entered: 06/12/2013) 1 Civil Cover Sheet Civil Cover Sheet View on PACER	June 12, 2013	June 12, 2013 RECAP
	Case Assigned to Judge Richard J. Leon. (ls, )	June 12, 2013	June 12, 2013 PACER
2	CIVIL COVER SHEET (Amended) by LARRY E. KLAYMAN re 1 Complaint filed by LARRY E. KLAYMAN. Related document: 1 Complaint filed by LARRY E. KLAYMAN.(Klayman, Larry) (Entered: 06/12/2013)	June 12, 2013	June 12, 2013 PACER
3	NOTICE OF RELATED CASE by All Plaintiffs. Case related to Case No. 13-cv-851. (Klayman, Larry) (Entered: 06/12/2013)	June 12, 2013	June 12, 2013 PACER
4	STANDING ORDER. Signed by Judge Richard J. Leon on 6/12/13. (lcrjl1) (Entered: 06/12/2013)	June 12, 2013	June 12, 2013 PACER
5	NOTICE of Appearance by James R. Whitman on behalf of DEPARTMENT OF JUSTICE OF THE UNITED STATES, NATIONAL SECURITY AGENCY (Whitman, James) (Entered: 06/14/2013)	June 14, 2013	June 14, 2013 PACER
6	MOTION for Extension of Time to Certify Class Action by LARRY E. KLAYMAN (Attachments: # 1 Text of Proposed Order)(Klayman, Larry) (Entered: 09/30/2013)	Sept. 30, 2013	Sept. 30, 2013 PACER
7	REQUEST FOR SUMMONS TO ISSUE by LARRY E. KLAYMAN re 1 Complaint filed by LARRY E. KLAYMAN. Related document: 1 Complaint filed by LARRY E. KLAYMAN. (Attachments: # 1 Summons, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons, # 9 Summons, # 10 Summons, # 11 Summons, # 12 Summons, # 13 Summons, # 14 Summons, # 15 Summons, # 16 Summons, # 17 Summons, # 18 Summons, # 19 Summons, # 20 Summons, # 21 Summons, # 22 Summons, # 23 Summons, # 24 Summons, # 25 Summons, # 26 Summons, # 27 Summons)(Klayman, Larry) (Entered: 10/08/2013)	Oct. 8, 2013	Oct. 8, 2013 PACER
8	ELECTRONIC SUMMONS (7) Issued as to KEITH B. ALEXANDER, DEPARTMENT OF JUSTICE OF THE UNITED STATES, ERIC H. HOLDER, JR, NATIONAL SECURITY AGENCY, BARACK HUSSEIN OBAMA, II, U.S. Attorney and U.S. Attorney General (znmw, ) (Entered: 10/09/2013)	Oct. 9, 2013	Oct. 9, 2013 PACER
9	Electronic Summons (21) Issued as to AOL, APPLE, TIM ARMSTRONG, AT&T, STEVE BALLMER, TONY BATES, TIMOTHY COOK, FACEBOOK, GOOGLE INC., DANIEL HEESE, SALAR KAMANGAR, JASON KATZ, MARISSA MEYER, MICROSOFT, LARRY PAGE, SKYPE, SPRINT COMMUNICATIONS COMPANY, RANDALL L. STEPHENSON, YAHOO! INC., YOUTUBE, LLC, MARK ZUCKERBERG. (Attachments: # 1 Notice and Consent)(znmw, ) (Entered: 10/09/2013) 1 Notice and Consent View on PACER	Oct. 9, 2013	Oct. 9, 2013 RECAP
10	MOTION for Preliminary Injunction by LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Memorandum in Support, # 2 Exhibit 1 -- Affidavit of Larry Klayman, # 3 Exhibit 2 -- Affidavit of Charles Strange, # 4 Text of Proposed Order)(Klayman, Larry) (Entered: 10/29/2013) 1 Memorandum in Support View on RECAP 2 Exhibit 1 -- Affidavit of Larry Klayman View on PACER 3 Exhibit 2 -- Affidavit of Charles Strange View on PACER 4 Text of Proposed Order View on PACER	Oct. 29, 2013	Oct. 29, 2013 RECAP
	Minute Order. Scheduling Conference set for 10/31/2013 at 03:45 PM in Courtroom 18 before Judge Richard J. Leon. (lcrjl1, )	Oct. 29, 2013	Oct. 29, 2013 PACER
11	MOTION for Extension of Time to Certify Class Action by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Text of Proposed Order)(Klayman, Larry) (Entered: 10/29/2013)	Oct. 29, 2013	Oct. 29, 2013 PACER
12	MOTION For Leave of Court To Take FRCP Rule 30(B)(6) Deposition re 10 MOTION for Preliminary Injunction by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Exhibit 1 -- Government's Opposition to ACLU's Motion for Preliminary Injunction, # 2 Text of Proposed Order)(Klayman, Larry) (Entered: 10/30/2013)	Oct. 30, 2013	Oct. 30, 2013 PACER
13	MOTION for Extension of Time to File Response/Reply as to 10 MOTION for Preliminary Injunction by KEITH B. ALEXANDER, DEPARTMENT OF JUSTICE OF THE UNITED STATES, ERIC H. HOLDER, JR, NATIONAL SECURITY AGENCY, BARACK HUSSEIN OBAMA, II (Attachments: # 1 Text of Proposed Order)(Gilligan, James) (Entered: 10/30/2013)	Oct. 30, 2013	Oct. 30, 2013 PACER
14	MOTION For Leave of Court to Appear Telephonically re Set Hearings by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Text of Proposed Order)(Klayman, Larry) (Entered: 10/30/2013)	Oct. 30, 2013	Oct. 30, 2013 PACER
15	NOTICE of Consent by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE re 14 MOTION For Leave of Court to Appear Telephonically re Set Hearings (Klayman, Larry) (Entered: 10/30/2013)	Oct. 30, 2013	Oct. 30, 2013 PACER
	MINUTE ORDER denying 14 Motion for Leave to Appear Telephonically. It is hereby ORDERED that plaintiffs' Motion for Leave to Appear Telephonically at the Scheduling Conference set for 10/31/2013 at 03:45 PM in Courtroom 18 before Judge Richard J. Leon is DENIED. Signed by Judge Richard J. Leon on 10/30/2013. (lcrjl1, )	Oct. 30, 2013	Oct. 30, 2013 PACER
16	MOTION to Continue Status Conference Concerning Preliminary Injunction by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Text of Proposed Order)(Klayman, Larry) (Entered: 10/30/2013) 1 Text of Proposed Order View on PACER	Oct. 30, 2013	Oct. 30, 2013 PACER
	MINUTE ORDER denying 16 Motion to Continue. It is hereby ORDERED that plaintiffs' Motion to Continue the Scheduling Conference set for 10/31/2013 at 03:45 PM in Courtroom 18 before Judge Richard J. Leon is DENIED. Signed by Judge Richard J. Leon on 10/31/2013. (lcrjl1, )	Oct. 31, 2013	Oct. 31, 2013 PACER
17	MOTION for Reconsideration re Order on Motion to Continue, by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Exhibit 1, # 2 Text of Proposed Order)(Klayman, Larry) (Entered: 10/31/2013) 1 Exhibit 1 View on PACER 2 Text of Proposed Order View on PACER	Oct. 31, 2013	Oct. 31, 2013 PACER
	MINUTE ORDER denying 17 Motion for Reconsideration. It is hereby ORDERED that Plaintiffs' Motion for Reconsideration of 16 Plaintiffs' Motion to Continue is DENIED. Signed by Judge Richard J. Leon on 10/31/2013. (lcrjl1, )	Oct. 31, 2013	Oct. 31, 2013 PACER
	Minute Entry: Status Conference held on 10/31/2013 before Judge Richard J. Leon: Plaintiff counsel not present. Transcript of the hearing will be sent to plaintiff counsel. Response to Preliminary Injunction Motion due by 11/11/2013. Reply due by 11/14/2013. Oral arugment set for 11/18/2013 at 11:30 AM in Courtroom 18 before Judge Richard J. Leon. (Court Reporter Patty Gels) (tb, )	Oct. 31, 2013	Oct. 31, 2013 PACER
18	MOTION For Leave to File Supplemental Declaration re 10 MOTION for Preliminary Injunction by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Exhibit 1 -- Declaration of Professor Edward Felten, # 2 Exhibit 2 -- Washington Post Article, # 3 Text of Proposed Order)(Klayman, Larry) (Entered: 11/01/2013)	Nov. 1, 2013	Nov. 1, 2013 PACER
	MINUTE ORDER granting 18 MOTION for Leave to File Supplemental Declaration. It is hereby ORDERED that plaintiffs' motion is GRANTED and the Declaration of Professor Edward W. Felten is accepted for filing. Signed by Judge Richard J. Leon on 11/6/2013. (lcrjl1, )	Nov. 6, 2013	Nov. 6, 2013 PACER
19	Supplemental Declaration re 10 MOTION for Preliminary Injunction by LARRY E. KLAYMAN. (znmw, ) (Entered: 11/08/2013)	Nov. 6, 2013	Nov. 6, 2013 PACER
20	Unopposed MOTION for Leave to File Excess Pages in the Combined Opposition to Plaintiffs' Preliminary Injunction Motions by KEITH B. ALEXANDER, DEPARTMENT OF JUSTICE OF THE UNITED STATES, ERIC H. HOLDER, JR, NATIONAL SECURITY AGENCY, BARACK HUSSEIN OBAMA, II (Attachments: # 1 Text of Proposed Order)(Patton, Rodney) (Entered: 11/08/2013)	Nov. 8, 2013	Nov. 8, 2013 PACER
	MINUTE ORDER granting 20 Motion for Leave to File Excess Pages. It is hereby ORDERED that the motion is GRANTED and that the page limit for Government Defendants' combined opposition is enlarged from 45 to 65 pages. Signed by Judge Richard J. Leon on 11/8/2013. (lcrjl1, )	Nov. 8, 2013	Nov. 8, 2013 PACER
21	Memorandum in opposition to re 10 MOTION for Preliminary Injunction filed by KEITH B. ALEXANDER, DEPARTMENT OF JUSTICE OF THE UNITED STATES, ERIC H. HOLDER, JR, NATIONAL SECURITY AGENCY, BARACK HUSSEIN OBAMA, II. (Attachments: # 1 Declaration (Declaration of James J. Gilligan), # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Exhibit T, # 22 Text of Proposed Order)(Gilligan, James) (Entered: 11/12/2013)	Nov. 12, 2013	Nov. 12, 2013 RECAP
22	Unopposed MOTION For Leave To File Reply Brief With Extended Pages And A Supplemental Declaration by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Exhibit 1 -- Supplemental Declaration of Professor Edward Felton, # 2 Text of Proposed Order)(Klayman, Larry) (Entered: 11/12/2013)	Nov. 12, 2013	Nov. 12, 2013 PACER
	MINUTE ORDER granting 22 Motion for Leave to File Reply Brief with Extended Pages and a Supplemental Declaration. It is hereby ORDERED that the motion is GRANTED and that the page limit for Plaintiffs' reply is enlarged from 25 to 50 pages; and it is further ordered that the Supplemental Declaration of Professor Edward W. Felten is accepted for filing. Signed by Judge Richard J. Leon on 11/12/2013. (lcrjl1, )	Nov. 12, 2013	Nov. 12, 2013 PACER
23	MOTION for Extension of Time to Certify Class Action by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Text of Proposed Order)(Klayman, Larry) (Entered: 11/12/2013)	Nov. 12, 2013	Nov. 12, 2013 PACER
24	Supplemental Declaration of Dr. Edward Felton by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE. (jf, ) (Entered: 11/13/2013)	Nov. 12, 2013	Nov. 12, 2013 PACER
25	MOTION for Extension of Time to File Response/Reply to Plaintiffs' Two Preliminary Injunction Motions by KEITH B. ALEXANDER, DEPARTMENT OF JUSTICE OF THE UNITED STATES, ERIC H. HOLDER, JR, NATIONAL SECURITY AGENCY, BARACK HUSSEIN OBAMA, II (Attachments: # 1 Text of Proposed Order)(Patton, Rodney) (Entered: 11/13/2013)	Nov. 13, 2013	Nov. 13, 2013 PACER
26	REPLY to opposition to motion re 10 MOTION for Preliminary Injunction filed by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE. (Attachments: # 1 Exhibit 1--, # 2 Exhibit 2 -- Supplemental Affidavit of Larry Klayman, # 3 Exhibit 3 -- NSA Touhy Request, # 4 Text of Proposed Order)(Klayman, Larry) (Entered: 11/15/2013)	Nov. 14, 2013	Nov. 14, 2013 PACER
	MINUTE ORDER granting, nunc pro tunc, 25 Government Defendants' Motion for Extension of Time to File Combined Opposition to Plaintiffs' Two Motions for Preliminary Injunctions. Signed by Judge Richard J. Leon on 11/15/2013. (lcrjl1, )	Nov. 15, 2013	Nov. 15, 2013 PACER
27	NOTICE of Filing of Amended Proposed Order by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE re 10 MOTION for Preliminary Injunction (Attachments: # 1 Certificate of Service)(Klayman, Larry) (Entered: 11/15/2013)	Nov. 15, 2013	Nov. 15, 2013 PACER
28	MOTION to Amend/Correct 1 Complaint by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Exhibit 1 -- Amended Complaint, # 2 Text of Proposed Order)(Klayman, Larry) (Entered: 11/17/2013) 1 Exhibit 1 -- Amended Complaint View on RECAP 2 Text of Proposed Order View on PACER	Nov. 17, 2013	Nov. 17, 2013 PACER
29	MOTION for Leave to File Supplemental Affidavit re 10 MOTION for Preliminary Injunction by MICHAEL FERRARI, MATT GARRISON, LARRY E. KLAYMAN, CHARLES STRANGE (Attachments: # 1 Exhibit 1 -- Affidavit of David Siler, # 2 Text of Proposed Order)(Klayman, Larry) (Entered: 11/17/2013)	Nov. 17, 2013	Nov. 17, 2013 PACER
	MINUTE ORDER granting 28 Plaintiffs' Motion for Leave to File Amended Complaint. It is hereby ORDERED that the motion is GRANTED and that Plaintiffs' Amended Complaint is accepted for filing. Signed by Judge Richard J. Leon on 11/23/2013. (lcrjl1, )	Nov. 23, 2013	Nov. 23, 2013 PACER

Case: Klayman v. Obama

1:13-cv-00881 | U.S. District Court for the District of District of Columbia

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