1

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA


LARRY KLAYMAN,

Plaintiff,
v.

JUDICIAL WATCH

Defendant.






Case No: 1:13-cv-20610-CMA



UNOPPOSED MOTION FOR LEAVE TO EXCEED PAGE LIMIT

Plaintiff, Larry Klayman (Plaintiff), hereby moves this Court for an additional five (5)
pages to respond to Defendant's Motion for Summary Judgment and as grounds therefor would
show:
1. On February 28, 2014, Defendant filed its Motion for Summary Judgment and Statement
of Material Facts, which were incorporated by reference into the motion.
2. Defendant's pleadings totaled thirty pages, as they have now incorporated discovery into
the Motion for Summary Judgment.
3. Plaintiff must similarly oppose the Motion for Summary Judgment by using information
gained through discovery.
4. Given the number of issues involved in this case, and the amount of discovery that must
be incorporated into the opposition, Plaintiff requires a short amount of additional
pleading space in order to fully oppose Defendant's motion.
5. Exceeding the page limit of twenty (20) pages by no more than five (5) pages will allow
Plaintiff the additional space necessary to oppose Defendant's motion.
Case 1:13-cv-20610-CMA Document 95-1 Entered on FLSD Docket 03/26/2014 Page 1 of 3

PDFaid.Com
#1 Pdf Solutions
2
6. Plaintiff contacted Defendant's counsel to seek consent for this motion. Defendant's
counsel indicated that he will not object to the additional five (5) pages sought in this
motion.

WHEREFORE, Plaintiff respectfully requests that this Court grant leave for Plaintiff to
exceed the page limit on his Opposition to Defendant's Motion for Summary Judgment by no
more than five (5) pages, for a total of twenty-five (25) pages.

Dated: March 17, 2014

Respectfully Submitted,

/s/ Larry Klayman
LARRY KLAYMAN
2520 Coral Way, Suite 2027
Miami, FL 33145
(310) 595-0800
leklayman@gmail.com

Plaintiff Pro Se


Case 1:13-cv-20610-CMA Document 95-1 Entered on FLSD Docket 03/26/2014 Page 2 of 3

3
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 17, 2014, I electronically filed the foregoing
document with the Clerk of the Court using the CM/ECF filing system. I also certify that the
foregoing document is being served this date on all counsel of record or pro se parties on the
attached Service List in the manner specified, either via transmission of Notices of Electronic
Filing generated by the CM/ECF system or in some other authorized manner for those counsel or
parties who are not authorized to receive electronically Notices of Electronic Filing.


/s/ Larry Klayman
LARRY KLAYMAN

Plaintiff Pro Se



SERVICE LIST

Douglas James Kress
Schwed Kahle & Jenks, P.A.
11410 North Jog Road
Suite 100
Palm Beach Gardens, FL 33418
561-694-0070
Fax: 561-694-0057
Email: dkress@schwedpa.com

VIA CM/ECF



Case 1:13-cv-20610-CMA Document 95-1 Entered on FLSD Docket 03/26/2014 Page 3 of 3