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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

LARRY KLAYMAN,

Plaintiffs,
v.

HONORABLE COLLEEN KOLLAR-KOTELLY,
Et. Al,

Defendant.
Civil Action No: 1:11-cv-01775





PLAINTIFF'S MOTION TO DISCLOSE EX PARTE COMMUNICATIONS WITH
JUDGE KOLLAR-KOTELLY, SENTELLE, ET. AL AND NOTICE OF INTENT TO
FILE MOTIONS FOR RECONSIDERATION AND/OR RULE 60 RELIEF FROM
JUDGMENT AND ORDER AND APPEAL IF NECESSARY


Plaintiff Larry Klayman hereby files the aforementioned motion and as grounds therefore
would show:
1) On the highest of holy days in the Jewish calendar, Yom Kippur (which spanned from
September 25-26 this year), the day of atonement, wherein Jews like Mr. Klayman
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pray for life,
God's forgiveness, and divine justice, this Court issued, filed, and served an Order and Final
Judgment and accompanying Memorandum which contains manifest errors of fact and law, and
effectively ignored Plaintiff's Motion for Change of Venue, which asked the court to transfer this
case to another judicial district, given its inherent conflict of interest in making any ruling in this
case.
2) Rather than first ruling upon and transferring this case to another judicial district, this
court effectively ignored Plaintiff's Motion to Change Venue, and on a sacred religious day to

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Klayman is a Jewish family name.
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Plaintiff, instead dismissed this case. In and of itself, that the court would choose Yom Kippur to
dismiss the case, a sacred holiday to Plaintiff, creates at least the appearance that indeed there is
and remains a conflict of interest in having this court rule upon issues involving the misconduct
of other jurists in this district. The appearance of issuing an Order and Final Judgment
dismissing this case on Yom Kippur
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, while Plaintiff was in Temple, speaks for itself and this is
why this court should not have ruled on any matter in this case but instead transferred it to the
U.S. District Court for the Eastern District of Pennsylvania, or another district unrelated to this
district.
3) Given the circumstances of the dismissal and refusal to even consider a change of
venue prior to making any rulings, among other compelling factors, Plaintiff respectfully moves
this court to disclose any and all relevant communications between the Honorable Richard J.
Leon and Judges Colleen Kollar-Kotelly, David Sentelle, Judith Rogers, Karen LeCraft
Henderson, David Tatel, Merrick Garland, Royce Lamberth, Rosemary Collyer, Beryl Howell,
and Robert Wilkin, all of whom are involved in the allegations of the complaint. Compl. ¶ 21.
This would include but not be limited to telephone records, emails, memoranda, notes, and other
evidence of communications concerning Larry Klayman, and/or this case, and what was
discussed. In addition, Plaintiff respectfully requests and moves this court to issue a sworn
statement as to whether, even if no written records exist, he communicated with these jurists
concerning Larry Klayman and/or this case. Such disclosure is necessary because Plaintiff
presently intends to file a Rule 60 Relief From Judgment Motion within 10 business days, which
will not only be based on this court's inherent conflict of interest in dismissing this case, but also

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At the same time, Yom Kippur, that this court was dismissing this case the President of Iran
was, in an affront to Jews, speaking to the United Nations calling for the annihilation of Israel
and the Jewish people.
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manifest errors of fact and law contained in Memorandum Opinion which supports the court's
Order and Final Judgment. If this motion does not succeed, Plaintiff will file an appeal and
petition for writ of mandamus forthwith before the U.S. Circuit Court of Appeals for the District
of Columbia.
4)This case presents serious issues of judicial ethics and judicial misconduct. The U.S.
District Court for the District of Columbia's and the Judicial Council's proclivity to cover up the
judicial misconduct cannot and should not be taken lightly, and for this reason Plaintiff
respectfully requests that this motion be granted on an expedited basis, within 5 business
days from the date herein, and the requested records disclosed to the parties.
Plaintiff has asked for the consent of opposing counsel. Defendants do not consent to this
motion.


Dated: September 27, 2012

Respectfully submitted,

/s/ Larry Klayman
Larry Klayman, Esq.
D.C. Bar No. 334581
Klayman Law Firm
2020 Pennsylvania Ave. NW, Suite 345
Washington, DC 20006
Tel: (310) 595-0800
Email: leklayman@gmail.com

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