Montgomery [and Klayman!] v. Comey (D.D.C.)

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bob
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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#76

Post by bob » Wed Jul 19, 2017 4:19 pm

Newsmax: House Intel Committee Should Speak With Whistleblower Montgomery:
Klayman wrote:For months I labored on Capitol Hill, going door to door like a “thirty something” young attorney, in effect lobbying not just the House Intelligence Committee to interview my client, Dennis Montgomery, an NSA/CIA whistleblower about his intimate knowledge of this continuing unconstitutional mass surveillance, not just on millions of Americans without probable cause that they were in the act of committing crimes or communicating with terrorists, but also the chief justice of the Supreme Court, other justices, 156 judges, and even President Trump and his staff and family while he was a private businessman. I advised the committee that Montgomery, under grant of immunity, had turned over 47 hard drives with over 600 million pages of information, much of it classified, to FBI Director James Comey and his special agents for investigation. I advised further that Comey had appeared to “bury” the investigation, as it would show, according to Montgomery, that the FBI itself, under Comey and before that former Director Robert Mueller, orchestrated this illegal and constitutional mass surveillance.

When I could not get a meeting to “meet” with Chairman Devin Nunes, I then wrote to each member of the committee, both Republican and Democrat, asking simply that any one or all of them interview Montgomery, as this was the potentially the biggest scandal in American history. Not one of them contacted me back[.]

* * *

[W]hy then not at least also talk to Montgomery, who was interviewed by Comey’s FBI special agents [ * * * ] for over three hours. Montgomery even agreed to be videotaped. Indeed, a few weeks ago I filed a lawsuit over Comey’s illegal surveillance and his obstruction of justice alleging that he buried the Montgomery investigation and this case is now progressing through the courts, with a preliminary injunction hearing to be set in August 2017. I have also asked the court to allow me to take the oral testimony of Comey himself, along with former Obama Director of National Intelligence James Clapper and former Obama Central Intelligence Director John Brennan, who Montgomery says also ordered the illegal mass surveillance.
Did Klayman go door-to-door shoeless, like Taitz did? Or door-to-door throwing CDs at congressional flak catchers, like Volin did?


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#77

Post by Foggy » Wed Jul 19, 2017 5:02 pm

Not one of them contacted me back.
Wow, it's almost as if they know who he is, and he's unpopular. Weird. :confused:


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#78

Post by bob » Fri Jul 28, 2017 12:02 pm

Klayman (and Montgomery!) moved for expedited discovery (on July 6); the federal government opposed (and noted Obama and Brennan haven't even been served); and the reply.

Klayman had trotted out this pony before. :yawn: The opposition notes Klayman's previous cases (which are surprisingly not yet dead), but refers to them as "Klayman v. Trump." Klayman originally sued Obama, but the suit was narrowed to mean that Obama was only being sued in his official capacity, i.e., as the president. Now that Obama is no longer the president, his successor automatically becomes the defendant.


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#79

Post by Notorial Dissent » Fri Jul 28, 2017 1:28 pm

Hasn't it placed last in show every time? Why should this be any different? Oh, wait GIL.


The fact that you sincerely and wholeheartedly believe that the “Law of Gravity” is unconstitutional and a violation of your sovereign rights, does not absolve you of adherence to it.

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#80

Post by bob » Sat Jul 29, 2017 2:18 pm

WND: TOP FBI LAWYER AND COMEY ALLY UNDER CRIMINAL INVESTIGATION:
Exclusive: Larry Klayman recalls James Baker's role in burying proof of illegal spying
Unsubstantiated (at least at this point) RWNJ rumors snipped. The more interesting stuff:
When I first met Montgomery through my client, Sheriff Joe Arpaio’s chief investigator Mike Zullo, years ago, I decided that we needed to bring this major whistleblower in from the cold – after no one in Congress or elsewhere in government would take the time, much more fortitude, to listen to what he had to say. To do this, I went to the only person in Washington, D.C., during the Obama years whom I totally trusted. His name is Royce C. Lamberth, and he is the only federal judge who had the courage to hold Bill and Hillary Clinton’s feet to the fire for their myriad of scandals during their White House years. While the judge always acted ethically, as I did, many in the leftist media believed that he and I were working together to “persecute” the Bonnie and Clyde of American politics.

After I left Judicial Watch to run for the U.S. Senate in Florida in 2003-2004, and later founded Freedom Watch, I took the opportunity to finally pay my respects to the judge who had done so much for the American people, and had taken a lot of heat for it with the vile crowd of Clinton loyalists who were trained to destroy anyone and anything in their march to regain control of the government. When I met with him, we reminisced about our independent but parallel exploits, and I thanked him for his integrity to do what is right, regardless of which political party is involved. I firmly believe that he is only one of a few federal judges in the nation whose rulings are not influenced by politics or his personal biases. (Years ago, he held a Republican secretary of the interior, Gale Norton, in contempt over misuse of Indian trust funds).

When I met with Montgomery, I realized that perhaps this courageous jurist could help pave the way for someone in government to listen to my client, who had come forward with perhaps the biggest scandal in American history.

Having asked Judge Lamberth how he thought it best to proceed, he recommended first that I take Montgomery to the soon-to-be Republican chairman of the Senate Judiciary Committee, Charles Grassley of Iowa. But after contacting him and having then met with his staff, they proved to be uniformly unhelpful, instead suggesting that I take Montgomery to the inspector general of the Defense Department. This was absurd. Why would I hand my client over to an Obama-run department, when he had the goods on illegal spying during Obama’s administration, among others?

When I took this back to the judge, he then recommended that we go see former FBI Director James Comey. After all, during the years of the prior Bush administration, as then-deputy attorney general, Comey had stood up to those in the administration who thought warrantless wiretaps on American citizens, in the wake of Sept. 11, were a “peachy keen idea.” To make this connection, Lamberth suggested that we go see Comey’s general counsel, James Baker, whom he knew.

And so it was the judge and I and another member of my staff who soldiered over to the FBI and met with Baker, explaining to him what Montgomery had and what was at stake for the nation if his whistleblowing was not addressed. During at least two meetings in the general counsel’s office, one of which had three FBI special agents in attendance, I asked to meet with the director himself. Baker came back and told us this would not be necessary, as he would supervise the Montgomery investigation at the direction of Comey, keeping Comey apprised of its progress every step of the way. In addition, Baker helped arrange for Montgomery to get immunity to produce his hard drives and testify to the FBI. As as result, my client performed his part of the bargain. But ever since then, Baker, Comey and their corrupted FBI have apparently buried the information and testimony that Montgomery provided to them.


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#81

Post by Notorial Dissent » Sat Jul 29, 2017 3:21 pm

Is there anything in that load of self serving codswallop that is even remotely true other than some of the names?


The fact that you sincerely and wholeheartedly believe that the “Law of Gravity” is unconstitutional and a violation of your sovereign rights, does not absolve you of adherence to it.

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#82

Post by Sterngard Friegen » Sat Jul 29, 2017 4:07 pm

No.



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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#83

Post by Grumpy Old Guy » Sat Jul 29, 2017 4:51 pm

Notorial Dissent wrote:Is there anything in that load of self serving codswallop that is even remotely true other than some of the names?
That may be dubious as well.



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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#84

Post by bob » Fri Aug 04, 2017 8:19 pm

WND: Why I have to do feds' job on illegal surveillance:
Exclusive: Larry Klayman jabs DOJ, Congress for inaction on agencies' data collection

[ * * * ]

This week, we learned Congress, among several causes for its inaction, likely has been blackmailed. . . .

[ * * * ]

I was forced to file this suit because not just Congress, but our now neutered attorney general, Jeff Sessions, lacks the courage to confront the likes of Clapper and the intelligence agencies. All of them, without exception unfortunately, are obviously afraid that material in the so-called files of the Federal Bureau of Investigation (FBI), National Security Agency (NSA) and the Central Intelligence Agency will be used to smear their private and personal lives.
:roll: But I admit to lurving Klayman's headline.

Oh:
[T]his is why I have been pushing Judge Leon to move this new case quickly to a discovery, a preliminary injunction hearing and later trial. In this regard, I have requested the depositions of not just Clapper, but also Comey and his former FBI General Counsel James Baker, former Obama CIA Director John Brennan, and representative of the NSA and CIA to testify under oath in preparation for the evidentiary hearings. And, if the court does not grant this early discovery, I have put the court on notice that I will subpoena these persons to testify live at the preliminary injunction hearing, which should occur in the next weeks.
A hearing, of course, which occurs only at the court's discretion.


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#85

Post by bob » Mon Sep 11, 2017 3:50 pm

D.D.C. wrote:Defendants' Reply in Support of their Motion to Dismiss is due by 8/22/2017. SO ORDERED. Signed by Judge Richard J. Leon on 6/27/17.
This fell off my radar; any update (perhaps on PACER?) on the status of Klayman's motion for a preliminary injunction (and the defendants' motion to dismiss)?


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#86

Post by Northland10 » Mon Sep 11, 2017 6:11 pm

bob wrote:
D.D.C. wrote:Defendants' Reply in Support of their Motion to Dismiss is due by 8/22/2017. SO ORDERED. Signed by Judge Richard J. Leon on 6/27/17.
This fell off my radar; any update (perhaps on PACER?) on the status of Klayman's motion for a preliminary injunction (and the defendants' motion to dismiss)?
I am not at home so I did not pull any docs, but here is the docket from 1 Aug on.
08/01/2017 25 SECOND SUPPLEMENT re 23 REPLY to opposition to motion re 15 MOTION to Expedite Discovery Second Supplement filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) Modified event title on 8/2/2017 (znmw). (Entered: 08/01/2017)

08/01/2017 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Attachments: # 1 Memorandum in Support, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Text of Proposed Order)(Patton, Rodney) (Entered: 08/01/2017)

08/01/2017 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Text of Proposed Order)(Patton, Rodney) (Entered: 08/01/2017)

08/01/2017 28 Memorandum in opposition to re 7 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS. (Attachments: # 1 Memorandum in Support, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Text of Proposed Order)(Patton, Rodney) (Entered: 08/01/2017)

08/09/2017 29 MOTION for Extension of Time to respond to plaintiffs' complaint by JAMES R. CLAPPER, DAN COATS, JAMES B. COMEY, MIKE POMPEO, MICHAEL S. ROGERS (Attachments: # 1 Text of Proposed Order)(Whitman, James) (Entered: 08/09/2017)
08/09/2017 30 RESPONSE re 29 MOTION for Extension of Time to respond to plaintiffs' complaint filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Attachments: # 1 Exhibit)(Klayman, Larry) (Entered: 08/09/2017)

08/10/2017 MINUTE ORDER granting 29 Defendants' Motion for Extension of Time to File Dispositive Motion. Set/Reset Deadlines: Dispositive Motion due by 9/13/2017. Signed by Judge Richard J. Leon on 8/10/17. (lcrjl3) (Entered: 08/10/2017)

08/15/2017 31 MOTION for Extension of Time to File Response/Reply as to 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint, 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim by LARRY KLAYMAN, DENNIS MONTGOMERY (Klayman, Larry) (Entered: 08/15/2017)

08/17/2017 32 Memorandum in opposition to re 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint, 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/17/2017)

08/17/2017 33 RESPONSE re 28 Memorandum in Opposition, filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/17/2017)

08/24/2017 34 REPLY to opposition to motion re 15 MOTION to Expedite Discovery Third Supplement filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/24/2017)

08/25/2017 35 REPLY to opposition to motion re 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint, 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim filed by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS. (Johnson, Timothy) (Entered: 08/25/2017)

08/28/2017 MINUTE ORDER finding as moot 31 Motion for Extension of Time to File Response/Reply. Signed by Judge Richard J. Leon on 8/28/17. (lcrjl3) (Entered: 08/28/2017)


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#87

Post by rpenner » Mon Sep 11, 2017 7:27 pm

(PACER) https://ecf.dcd.uscourts.gov/cgi-bin/DktRpt.pl?187032
(RECAP) http://www.archive.org/details/gov.uscourts.dcd.187032

1:17-cv-01074-RJL MONTGOMERY et al v. COMEY et al

Grossly Inappropriate Case-in-Main + Miscellany:
06/05/2017 1 COMPLAINT against All Defendants with Jury Demand ( Filing fee $ 400 receipt number 0090-4977937) filed by Dennis Montgomery, Larry Klayman. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C, # 4 Civil Cover Sheet, # 5 Summons, # 6 Summons, # 7 Summons, # 8 Summons, # 9 Summons, # 10 Summons, # 11 Summons, # 12 Summons, # 13 Summons, # 14 Summons, # 15 Summons, # 16 Summons)(Klayman, Larry) (Entered: 06/05/2017)
06/05/2017 2 NOTICE OF RELATED CASE by All Plaintiffs. Case related to Case No. 13-cv-851. (Klayman, Larry) (Entered: 06/05/2017)
06/06/2017 3 ERRATA by Larry Klayman, Dennis Montgomery 1 Complaint, filed by Larry Klayman, Dennis Montgomery. (Klayman, Larry) (Entered: 06/06/2017)
06/06/2017 Case Assigned to Judge Richard J. Leon. (sb) (Entered: 06/06/2017)
06/06/2017 4 SUMMONS (6) Issued Electronically as to CENTRAL INTELLIGENCE AGENCY, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, BARACK HUSSEIN OBAMA, II, U.S. Attorney and U.S. Attorney General (Attachment: # 1 Consent Form)(sb) (Entered: 06/06/2017)
06/06/2017 SUMMONS Not Issued as to JOHN BRENNAN, JAMES R. CLAPPER, DAN COATS, JAMES B. COMEY, MIKE POMPEO, MICHAEL S. ROGERS.....SUMMONS INCOMPLETE AT THE TIME COMPLAINT WAS FILED. (sb) (Entered: 06/06/2017)
06/06/2017 5 REQUEST FOR SUMMONS TO ISSUE for Defendants Comey, Brennan, Rogers, Pompeo, Clapper, and Coats filed by DENNIS MONTGOMERY, LARRY KLAYMAN. (Attachments: # 1 Summons, # 2 Summons, # 3 Summons, # 4 Summons, # 5 Summons)(Klayman, Larry) (Entered: 06/06/2017)
06/07/2017 6 SUMMONS (6) Issued Electronically as to JOHN BRENNAN, JAMES R. CLAPPER, DAN COATS, JAMES B. COMEY, MIKE POMPEO, MICHAEL S. ROGERS. (sb) (Entered: 06/07/2017)
06/20/2017 Minute Entry: Scheduling Conference set for 6/23/2017 at 03:30 PM in Courtroom 18 before Judge Richard J. Leon. (lcrjl3) (Entered: 06/20/2017)
06/23/2017 Minute Entry for proceedings held before Judge Richard J. Leon: Case called for a Scheduling Conference, but not held. Status Conference held on 6/23/2017. (Court Reporter: William P. Zaremba) (jth) (Entered: 06/23/2017)
06/24/2017 10 NOTICE OF RELATED CASE by LARRY KLAYMAN, DENNIS MONTGOMERY. Case related to Case No. 13-00851, 13-00881, 14-00092. (Klayman, Larry) (Entered: 06/24/2017)
06/26/2017 11 NOTICE of Appearance by James J. Gilligan on behalf of CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Gilligan, James) (Entered: 06/26/2017)
06/27/2017 12 TRANSCRIPT OF STATUS CONFERENCE HEARING PROCEEDINGS before Judge Richard J. Leon held on June 23, 2017; Page Numbers: 1-39. Date of Issuance: June 27, 2017. Court Reporter/Transcriber: William Zaremba; Telephone number: (202) 354-3249. Transcripts may be ordered by submitting the Transcript Order Form

For the first 90 days after this filing date, the transcript may be viewed at the courthouse at a public terminal or purchased from the court reporter referenced above. After 90 days, the transcript may be accessed via PACER. Other transcript formats, (multi-page, condensed, PDF or ASCII) may be purchased from the court reporter.

NOTICE RE REDACTION OF TRANSCRIPTS: The parties have twenty-one days to file with the court and the court reporter any request to redact personal identifiers from this transcript. If no such requests are filed, the transcript will be made available to the public via PACER without redaction after 90 days. The policy, which includes the five personal identifiers specifically covered, is located on our website at http://www.dcd.uscourts.gov.

Redaction Request due 7/18/2017. Redacted Transcript Deadline set for 7/28/2017. Release of Transcript Restriction set for 9/25/2017.(wz) (Entered: 06/27/2017)
06/27/2017 MINUTE ORDER. Having considered the arguments submitted by the parties at the scheduling conference held 6/23/17, this Court has satisfied itself that--although a close call--this case is sufficiently related to Klayman v. Obama, 13-cv-851, for this Court to retain jurisdiction. Defendants are hereby ordered to submit any Opposition to Plaintiff's Motion for a Preliminary Injunction 7 and any Motion to Dismiss by 8/1/2017. Plaintiff is directed to file any Reply in Support of his Motion for a Preliminary Injunction and any Opposition to Defendants' Motion to Dismiss by 8/15/2017. Defendants' Reply in Support of their Motion to Dismiss is due by 8/22/2017. SO ORDERED. Signed by Judge Richard J. Leon on 6/27/17. (lcrjl3) (Entered: 06/27/2017)
06/27/2017 13 NOTICE of Appearance by Caroline J. Anderson on behalf of CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Anderson, Caroline) (Entered: 06/27/2017)
06/27/2017 Set/Reset Deadlines: Defendants Opposition to Plaintiffs Motion for a Preliminary Injunction and any Motion to Dismiss are due by 8/1/2017; Plaintiffs Reply in Support of the Motion for a Preliminary Injunction and Opposition to any Defendants Motion to Dismiss is due by 8/15/2017; Defendants' Reply in Support of any Motion to Dismiss is due by 8/22/2017. (jth) (Entered: 06/27/2017)
06/27/2017 14 NOTICE of Appearance by Timothy Andrew Johnson on behalf of CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Johnson, Timothy) (Entered: 06/27/2017)
07/10/2017 17 NOTICE of Appearance by Rodney Patton on behalf of CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Patton, Rodney) (Entered: 07/10/2017)
07/10/2017 18 NOTICE of Appearance by James R. Whitman on behalf of JAMES R. CLAPPER, DAN COATS, MICHAEL S. ROGERS (Whitman, James) (Entered: 07/10/2017)
07/20/2017 21 NOTICE of Appearance by James R. Whitman on behalf of MIKE POMPEO (Whitman, James) (Entered: 07/20/2017)
09/25/2017 Can Grab Jun 23 Status Conference Transcript [Based on Docket 10]

Grossly Inappropriate Motion for TRO: ⚠️ Fully Briefed
06/19/2017 7 MOTION for Temporary Restraining Order , MOTION for Preliminary Injunction by LARRY KLAYMAN, DENNIS MONTGOMERY (Klayman, Larry) (Entered: 06/19/2017)
06/23/2017 8 AFFIDAVIT re 7 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction Amended by LARRY KLAYMAN. (Klayman, Larry) (Entered: 06/23/2017)
06/23/2017 9 AFFIDAVIT re 7 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction Amended by DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 06/23/2017)
08/01/2017 28 Memorandum in opposition to re 7 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS. (Attachments: # 1 Memorandum in Support, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Text of Proposed Order)(Patton, Rodney) (Entered: 08/01/2017)
08/17/2017 33 RESPONSE re 28 Memorandum in Opposition, filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/17/2017)

26.1=27.1=28.1 The Memo.
26.2=27.3=28.2 2006 Sealed declaration of Dennis Montgomery in support of his Oppositions to DOD's and Intreppid's Motions for Protective Orders
26.3=27.4=28.3 2014 Motion opposing shenanigans.
26.4=27.5=28.4 Declaration of David M. Hardy (FBI Records Section Chief)
Plaintiffs Dennis Montgomery and Larry Klayman (“Plaintiffs” unless individually named) hereby submit the following in opposition to Government Defendants’ Motion to Dismiss, Motion for Partial Summary Judgment and in response to Opposition to Motion for Temporary Restraining Order. Because the Government Defendants filed identical briefs for all three documents, Plaintiffs will respond to each of the Government Defendants’ briefs with this memorandum of law.
https://www.youtube.com/watch?v=i2nuPVTU4Z4

Question: What odds would you have placed that Dockets 26.1, 27.1 and 28.1 would turn out to be actually identical? Dockets 32 and 33 seem nearly identical.

Grossly Inappropriate Motion to Expedite: ⚠️ Fully Briefed
07/06/2017 15 MOTION to Expedite Discovery by LARRY KLAYMAN, DENNIS MONTGOMERY (Klayman, Larry) (Entered: 07/06/2017)
07/20/2017 22 Memorandum in opposition to re 15 MOTION to Expedite Discovery filed by JOHN BRENNAN, CENTRAL INTELLIGENCE AGENCY, JAMES R. CLAPPER, DAN COATS, JAMES B. COMEY, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, BARACK HUSSEIN OBAMA, II, MIKE POMPEO, MICHAEL S. ROGERS. (Attachments: # 1 Text of Proposed Order)(Whitman, James) (Entered: 07/20/2017)
07/27/2017 23 REPLY to opposition to motion re 15 MOTION to Expedite Discovery filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 07/27/2017)
07/31/2017 24 SUPPLEMENT re 23 REPLY to opposition to motion re 15 MOTION to Expedite Discovery Supplement filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) Modified event title on 8/1/2017 (znmw). (Entered: 07/31/2017)
08/01/2017 25 SECOND SUPPLEMENT re 23 REPLY to opposition to motion re 15 MOTION to Expedite Discovery Second Supplement filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) Modified event title on 8/2/2017 (znmw). (Entered: 08/01/2017)
08/24/2017 34 REPLY to opposition to motion re 15 MOTION to Expedite Discovery Third Supplement filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/24/2017)

Grossly Inappropriate Motion Shorten time on Motion to Expedite: ❌
07/07/2017 16 MOTION Shorten Time to Respond to Plaintiffs' Motion for Expedited Discovery re 15 MOTION to Expedite Discovery by LARRY KLAYMAN, DENNIS MONTGOMERY (Klayman, Larry) (Entered: 07/07/2017)
07/11/2017 19 Memorandum in opposition to re 16 MOTION Shorten Time to Respond to Plaintiffs' Motion for Expedited Discovery re 15 MOTION to Expedite Discovery filed by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS. (Attachments: # 1 Text of Proposed Order)(Gilligan, James) (Entered: 07/11/2017)
07/11/2017 20 REPLY to opposition to motion re 16 MOTION Shorten Time to Respond to Plaintiffs' Motion for Expedited Discovery re 15 MOTION to Expedite Discovery filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 07/11/2017)
07/13/2017 MINUTE ORDER denying 16 Plaintiffs' Motion to Shorten Time to Respond to Plaintiffs' Motion to Expedite Discovery. Signed by Judge Richard J. Leon on 7/13/17.(lcrjl3) Modified event title on 7/14/2017 to reflect that this is a minute/paperless order (znmw). (Entered: 07/13/2017)


Motion to Dismiss: ⚠️ Fully Briefed
08/01/2017 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Attachments: # 1 Memorandum in Support, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Text of Proposed Order)(Patton, Rodney) (Entered: 08/01/2017)
8/15/2017 Opposition to any Defendants Motion to Dismiss is due [Based on June 27 Order]
08/17/2017 33 RESPONSE re 28 Memorandum in Opposition, filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/17/2017)
08/25/2017 35 REPLY to opposition to motion re 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint, 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim filed by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS. (Johnson, Timothy) (Entered: 08/25/2017)


Motion for Partial Summary Judgment: ⚠️ Fully Briefed
08/01/2017 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Text of Proposed Order)(Patton, Rodney) (Entered: 08/01/2017)
08/17/2017 32 Memorandum in opposition to re 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint, 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/17/2017)
08/17/2017 33 RESPONSE re 28 Memorandum in Opposition, filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Klayman, Larry) (Entered: 08/17/2017)
08/25/2017 35 REPLY to opposition to motion re 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint, 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim filed by CENTRAL INTELLIGENCE AGENCY, DAN COATS, FEDERAL BUREAU OF INVESTIGATION, NATIONAL SECURITY AGENCY, MIKE POMPEO, MICHAEL S. ROGERS. (Johnson, Timothy) (Entered: 08/25/2017)
A lengthy series of conclusory allegations and implausible claims form the basis of Plaintiffs’ Opposition to the Government Defendants’ Motion to Dismiss and Motion for Partial Summary Judgment (“Plaintiffs’ Opposition”), ECF No. 32, just as they form the basis of Plaintiffs’ Complaint, ECF No. 1. Evidently, Plaintiffs Larry Klayman and Dennis Montgomery hope that, if they repeat their baseless assertions of a Government conspiracy to conduct illegal surveillance against them enough times, across multiple filings and cases, the endless repetition alone will eventually make their claims for relief seem plausible. Instead, the combination of repetition with Plaintiffs’ dogged refusal to acknowledge how the legal terrain has changed since Plaintiff Klayman originally filed his related lawsuits,1 merely serves to emphasize how untethered Plaintiffs’ Complaint is to either well-pled fact or law.
1 Klayman v. Trump, 13-cv-851 (“Klayman I”); Klayman v. Trump, 13-cv-881 (“Klayman II”); and Klayman v. Trump, 14-cv-092 (“Klayman III”).
Individual Capacity Defendants' Motion for Extension of Time: ✅
08/09/2017 29 MOTION for Extension of Time to respond to plaintiffs' complaint by JAMES R. CLAPPER, DAN COATS, JAMES B. COMEY, MIKE POMPEO, MICHAEL S. ROGERS (Attachments: # 1 Text of Proposed Order)(Whitman, James) (Entered: 08/09/2017)
08/09/2017 30 RESPONSE re 29 MOTION for Extension of Time to respond to plaintiffs' complaint filed by LARRY KLAYMAN, DENNIS MONTGOMERY. (Attachments: # 1 Exhibit)(Klayman, Larry) (Entered: 08/09/2017)
08/10/2017 MINUTE ORDER granting 29 Defendants' Motion for Extension of Time to File Dispositive Motion. Set/Reset Deadlines: Dispositive Motion due by 9/13/2017. Signed by Judge Richard J. Leon on 8/10/17. (lcrjl3) (Entered: 08/10/2017)

Grossly Inappropriate Motion for Extension of Time: ❌
08/15/2017 31 MOTION for Extension of Time to File Response/Reply as to 27 MOTION for Partial Summary Judgment as to Count Six of Plaintiffs' Complaint, 26 MOTION to Dismiss for Lack of Subject-Matter Jurisdiction and Motion to Dismiss for Failure to State a Claim by LARRY KLAYMAN, DENNIS MONTGOMERY (Klayman, Larry) (Entered: 08/15/2017)
08/28/2017 MINUTE ORDER finding as moot 31 Motion for Extension of Time to File Response/Reply. Signed by Judge Richard J. Leon on 8/28/17. (lcrjl3) (Entered: 08/28/2017)
[Mootness explained by Docket 33]

Additional Individual Capacity Defendants' Dispositive Motion:
09/13/2017 ??? [Based on August 10 Order]



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Suranis
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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#88

Post by Suranis » Tue Sep 12, 2017 6:29 am

Notorial Dissent wrote:Is there anything in that load of self serving codswallop that is even remotely true other than some of the names?
It's actually all there if you use my patented kalyman-English translator, available mow for only 99 monthly payments of 99.99.

For example
When I met with him, we reminisced about our independent but parallel exploits, and I thanked him for his integrity to do what is right, regardless of which political party is involved.
Translates to

The Judge said "Who are you? What the fuck are you doing here in my house, wearing a sailor suit? GET OUT!"
Having asked Judge Lamberth how he thought it best to proceed,
"How the hell did you get this number? *slam*
When I took this back to the judge, he then recommended that we go see former FBI Director James Comey.
When the judge found me naked in his bed, he called security and the police.
And so it was the judge and I and another member of my staff who soldiered over to the FBI and met with Baker, explaining to him what Montgomery had and what was at stake for the nation if his whistleblowing was not addressed.
The Judge got a restraining order, as well as an injunction to never ever use the word "blowing" in any context near the judge, and to pay for the judges mental treatment due to the pictures I had sent him.

You see, easy. Buy your klayman English translator today!


Irony can be pretty ironic sometimes.

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#89

Post by Notorial Dissent » Tue Sep 12, 2017 6:38 am

:like: :thumbs: :rotflmao:


The fact that you sincerely and wholeheartedly believe that the “Law of Gravity” is unconstitutional and a violation of your sovereign rights, does not absolve you of adherence to it.

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#90

Post by Tesibria » Tue Sep 12, 2017 7:27 am

I'm very way late to the party here ...

Just a couple notes off top of my head, while I catch up on the details ...

About the hard drives ...

In November 2013, MCSO spent $2,100 on hard drives for the Seattle Operation. IOW, it is reasonable to assume that they made copies of Montgomery's drives.

About software on the hard drives ...

On October 21, 2015 -- after claiming repeatedly in the Risen litigation that the alleged software was on the drives turned over to the FBI, Montgomery declared under oath that "Based on my personal knowledge and belief, upon searching my memory, I do not believe that I have had access to any of the subject software, nor did I provide it to the Federal Bureau of lnvestigation ("FBI") when I turned over the drives pursuant to my immunity agreement of July 28, 2015 and the inventory of what I turned over. However, I am today providing some additional information (attached) which may allow the FBI to see if the software - in whole or in part - exists on the drives I turned over to the FBI to conduct its ongoing classification review.""

See also Transcript (and notes re: same) from the Jan. 26, 2016 hearing in Risen:
THE COURT: Your position -- and I want you to tell me if I'm wrong or not understanding this correctly -- your position is that Mr. Montgomery now realizes most likely that he no longer has the software at issue because the FBI removed it from his house illegally when he was tied to a tree; and when it was brought out that the FBI special agent lied in an affidavit, the judge ordered the seized materials to be returned, and apparently, although materials were returned, the software was not returned.

Do I have that right?

MR. KLAYMAN: That's the only logical explanation, based upon the fact that he now doesn't believe he has it and the FBI can't find it.


“Words are sacred. They deserve respect. If you get the right ones, in the right order, you can nudge the world a little.”― Tom Stoppard
WYE: Arpaio-Melendres-Seattle Operation Timeline | Sectec Astronomy: Dennis Montgomery Timeline

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#91

Post by Notorial Dissent » Tue Sep 12, 2017 2:36 pm

Yeah, right!!!! Because KKKlayman says it's so. What I'd really like to know is just how big those drives were that MCSO paid for and what type.


The fact that you sincerely and wholeheartedly believe that the “Law of Gravity” is unconstitutional and a violation of your sovereign rights, does not absolve you of adherence to it.

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#92

Post by RoadScholar » Tue Sep 12, 2017 3:26 pm

"...conclusory allegations and implausible claims..."

Heh.


The bitterest truth is healthier than the sweetest lie.
X3

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Notorial Dissent
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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#93

Post by Notorial Dissent » Tue Sep 12, 2017 3:49 pm

RoadScholar wrote:"...conclusory allegations and implausible claims..."

Heh.
In other words, standard GIL practice of law.


The fact that you sincerely and wholeheartedly believe that the “Law of Gravity” is unconstitutional and a violation of your sovereign rights, does not absolve you of adherence to it.

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#94

Post by ArthurWankspittle » Wed Sep 13, 2017 3:31 am

I can't remember exactly but wasn't Montgomery seriously ill back in November/December/January and hadn't got long in this world?


Going to Tibet now and deleting Facebook you have my email address.

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#95

Post by vic » Wed Sep 13, 2017 3:45 am

ArthurWankspittle wrote:I can't remember exactly but wasn't Montgomery seriously ill back in November/December/January and hadn't got long in this world?
My bet is on the first one...

Image



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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#96

Post by Tesibria » Wed Sep 13, 2017 6:39 am

ArthurWankspittle wrote:I can't remember exactly but wasn't Montgomery seriously ill back in November/December/January and hadn't got long in this world?
Since at least May 2014 ....


“Words are sacred. They deserve respect. If you get the right ones, in the right order, you can nudge the world a little.”― Tom Stoppard
WYE: Arpaio-Melendres-Seattle Operation Timeline | Sectec Astronomy: Dennis Montgomery Timeline

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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#97

Post by Northland10 » Wed Sep 13, 2017 7:48 am

I am of the belief that said "software" is, at the most, no more than a small collection of scripts used to automate pulling crap from the internet.


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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#98

Post by RTH10260 » Wed Sep 13, 2017 10:23 am

bob wrote:Newsmax: House Intel Committee Should Speak With Whistleblower Montgomery:
:snippity: :snippity:
Did Klayman go door-to-door shoeless, like Taitz did? Or door-to-door throwing CDs at congressional flak catchers, like Volin did?
Does anyone have evidence that Klayman was really visiting Capitol Hill as claimed? Would there be a visitors register?



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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#99

Post by Sterngard Friegen » Wed Sep 13, 2017 11:11 am

Montgomery is ill only when it suits his litigation objectives.



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Re: Montgomery [and Klayman!] v. Comey (D.D.C.)

#100

Post by Northland10 » Wed Sep 13, 2017 1:13 pm

Sterngard Friegen wrote:Montgomery is ill only when it suits his litigation objectives.
Including keeping him out of a Nevada jail.


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