IN UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA

LARRY KLAYMAN, on behalf of himself and all others similarly situated,2020 Pennsylvania Ave. NWSuite 800Washington, DC 20006andCHARLES AND MARY ANN STRANGE, on behalf of themselves and all others similarly situated,Philadelphia, PennsylvaniaPlaintiffs,v.BARACK HUSSEIN OBAMA II,1600 Pennsylvania Ave. NWWashington, DC 20500andERIC HIMPTON HOLDER, JR.,555 Fourth St. NWWashington, DC 20530andKEITH B. ALEXANDER Director of the National Security Agency,9800 Savage Rd.Fort Meade, MD 20755andLOWELL C. McADAM,Chief Executive Officer of Verizon Communications140 West Street New York, NY 10007andCivil Action No.: 1:13-cv-00851Judge Richard J. Leon Case 1:13-cv-00851-RJL Document 4 Filed 06/09/13 Page 1 of 24   2ROGER VINSON,Judge, U.S. Foreign Intelligence Surveillance Court950 Pennsylvania Ave. NWWashington, DC 20530andVERIZON COMMUNICATIONS,140 West Street New York, NY 10007and NATIONAL SECURITY AGENCY,Director of the National Security Agency,9800 Savage Rd.Fort Meade, MD 20755andTHE U.S. DEPARTMENT OF JUSTICE,950 Pennsylvania Ave. NWWashington, DC 20530Defendants. CLASS ACTION AMENDED COMPLAINT Plaintiff, Larry Klayman, a former U.S. Department of Justice prosecutor, and PlaintiffsCharles and Mary Ann Strange (collectively “Plaintiffs”) bring this action on their own behalf and on behalf of a class of persons defined below. Plaintiffs hereby sue Barack Hussein Obama,Eric Holder, Keith B. Alexander, Lowell McAdam, Roger Vinson, Verizon Communications, theU.S. Department of Justice (“DOJ”), and the National Security Agency (“NSA”), (collectively“Defendants”), in their personal and official capacities, for violating Plaintiffs’ constitutionalrights, Plaintiffs’ reasonable expectation of privacy, free speech and association, right to be freeof unreasonable searches and seizures, and due process rights, as well as certain common lawclaims, for directly and proximately causing Plaintiffs mental and physical pain and suffering Case 1:13-cv-00851-RJL Document 4 Filed 06/09/13 Page 2 of 24   3and harm as a result of the below pled illegal and criminal acts. Plaintiffs and members of theclass pled below allege as follows: INTRODUCTION 1.   This is an action for violations of the First, Fourth, and Fifth Amendments to the U.S.Constitution. This is also an action for violations of privacy, including intrusion uponseclusion, freedom of expression and association, due process, and other illegal acts.Plaintiffs bring this action on behalf of themselves and all other similarly situated consumers,users, and U.S. citizens who are customers and users of Defendant Verizon Communications(“Verizon”).2.   This case challenges the legality of Defendants’ participation and conduct in a secret andillegal government scheme to intercept and analyze vast quantities of domestic telephoniccommunications. Specifically, on June 5, 2013, The Guardian posted a classified order fromthe secretive Foreign Intelligence Surveillance Court directing Verizon to turn over, “on anongoing daily basis,” the following tangible things: “All call detail records or “telephonymetadata” created by Verizon for communications (i) between the United States and abroad;or (ii) wholly within the United States, including local telephone calls.”3.   This would give the NSA over one hundred millions phone records on a daily basis. Theinformation would also include a list of all the people that Verizon customers call and whocalled them; how long they spoke; and perhaps, where they were on a given day. Further,there is nothing in the order requiring the government to destroy the records after a certainamount of time nor is there any provisions limiting who can see and hear the data.4.    The order, issued and signed by Judge Roger Vinson, violates the U.S. Constitution and alsofederal laws, including, but not limited to, the outrageous breach of privacy, freedom of speech, freedom of association, and the due process rights of American citizens. Case 1:13-cv-00851-RJL Document 4 Filed 06/09/13 Page 3 of 24

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  • 3 billion is chump change for these fools.  

  • $3 billion?

    "Larry Klayman on behalf of Charles and Mary Ann Strange." Suing. Yep, sounds like the USA alright. But $3 billion? Fat chance. That's a lot of money. If they include in the papers that they're giving all the money to charity, then maybe I won't think they're greedy snobs.

    "for directly and proximately causing Plaintiffs mental and physical pain and suffering." Yeah right. The government isn't going to pay you $3 billion because you're paranoid and stressed about what people may, or may have not, found out about you. Or maybe they're just publicity whores.

    I'm not surprised about this actually. And I'm wondering how many more people are going to waste the court system's time with this.

    First of all, isn't USA broke? How do you get money from someone that doesn't have money to give? They gonna borrow it from China?

    Second of all, this affects all of the USA. Not just these two sue-happy greedsters. That means it effects the judge, the jury, and their family. Why do these two blokes get money and not everyone?

    Get over it already. If you don't want the USA protecting you and you're gonna sue over it... GTFO!

    Do people really think their secrets are that juicy that they have to get that mad over it? I bet they're lame and boring.

    • DREAMSICLE: there were people in Nazi Germany who said exactly what you are saying, and they  didn't care about the SS and similar intelligence gatherers going after those gosh darn gypsies and jews until they themselves got rounded up (along with those gypsies and jews) for the sake of the "new economy.". YOU ARE F-WORD STUPID IF YOU BELIEVE THE GOVERNMENT WILL NOT HURT YOU IN EVENT OF A NATIONAL CRISIS BASED ON YOUR GOOD BEHAVIOR. Maybe you wouldn't mind if a computer tracks you and knows everything you do, but I believe I have a right to privacy. IT'S NONE OF THE GOVERNMENTS BUSINESS REGARDING WHAT I SAID TO MY GIRLFRIEND OR WHAT UNDERWEAR SHOW I MAY WANT TO CHECK OUT ON THE INTERNET, WITH MY GIRLFRIEND OR OTHERWISE. You need to check out life outside of Britain, because I see a lot of blokes from England coming into Austin for the SXSW festival, and I'm shocked at how well conditioned they are with their love for big government telling them what means they have to protect themself with from criminals and their fear of retribution for critisizing their government that they pay taxes to.

      • Malcolm:  But I LOVE the SS!  "I've got nothing to hide!"

      • Malcolm:  Oh yes, THE FEAR, THE FEAR, they are here to "protect" you, Ha!

      • Teehee... I'm American. I've never been to the UK. So... my life IS outside of Britain.

         

        If something happens to me in the situation that you describe, it's going to cause quite a controversy. And it won't be quite. And I'm sure it's like that for a lot of people. -- If things boil down to that... something is seriously wrong with the world at that point and the government would be the least of the problems.

        I did not live a sheltered life. I am very well aware of the evils of the world and individuals. Maybe it's because I'm not sheltered, that I'm not scared or concerned.

        You can't run over your neighbors cat without the world hearing about it these days (I didn't say that happened, it didn't, just a metaphor). Because the same day that cat will have a support group on facebook or something of the like if it didn't already have it's own page to begin with.

        So if something happens like you are describing (and assuming it's a big thing and not just little ol' me)... the people will rally. Specially after this whole "gun buying surge" where people went on a shopping spree emptying store shelves. The world is not going to sit back and watch the holocaust or something similar happen all over again. I mean really.

        Also, that "lack of privacy" can also help you. Cell phones these days with their gps and location tracking. Who needs to create an alibi when the phone logs one for you?

        • Dreamsicle:  Oh, yes, being tracked is WONDERFUL.

        • Since you are from Indiana, then let me ask you this: the courts in your Indiana home state just ruled that if the police enter your house without a warrant and physically hurt you, you can't do anything about it in a court of law. HOW ABOUT ADVERTISING YOU NAME, ADDRESS, AND PHONE NUMBER WITH A REPLY TO THIS MESSAGE SO THAT EVERYONE IN THE INTERNET (including the Indiana police) KNOWS HOW YOU FEEL ABOUT PROTECTING YOUR SELF?

          • Malcolm:  I've got "Nothing To Hide" so why should I worry?

          • Lol. I'm not from Indiana, or even in Indiana. If you've read any of my discussions you'll understand the irony of the location in my profile. 

            Are they gonna take me out to dinner and light scented candles before this takes place?

            All kidding aside. I don't need to advertise anything. All someone needs to do is look up my IP address to figure out this information. If someone wants me they gotta work for it ;)  xP lol

            No. But obviously that law sounds pretty messed up. Do you really think I'm going to sit here and tell you, "oh hell yeah, I love me a good ol' assault and battery!"... are you nuts?

            But IF that happened to me, videos of the assault would be put up on youtube faster than you can press three buttons on a cellphone (not to mention witnesses). Also, considering there's no reason for them to be in my house or assaulting me or my family to begin with... a lawyer would put a smackdown on them.

            Do you have a link to that law?

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