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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA


STRANGE, et. al

Plaintiffs,
v.

ISLAMIC REPUBLIC OF IRAN, et al

Defendants.







Civil Action No. 1:14-cv-00435





AFFIDAVIT OF DOUGLAS HAMBURGER IN SUPPORT OF MOTION FOR
DISQUALIFICATION PURSUANT TO 28 U.S.C. 144


1. My name is Douglas Hamburger, I am over 18 years old. I am an adult citizen of the United
States and I am a plaintiff in the above styled case. I have personal knowledge of the facts
stated in this declaration.
2. I have been made aware that my attorney, Larry Klayman, has been in long-running litigation
with the judge currently assigned to this case, the Honorable Colleen Kollar-Kotelly. See
Klayman v. Kotelly, 2013 U.S. App. LEXIS 26059 (D.C. Cir. Oct. 22, 2013); Klayman v.
Kollar-Kotelly, 892 F. Supp. 2d 261 (D.D.C. 2012).
3. I have been made aware that the appellate process is still active and ongoing, and that a
petition for writ of certiorari will be filed before the U.S. Supreme Court on May 12, 2014.
4. In a case of such importance as this one, where it is the families of the fallen heroes of Navy
SEAL Team Six and other Special Forces operatives who are attempting to gain justice for
our lost loved ones, Judge Kollar-Kotelly's long-running litigation with my attorney will
Case 1:14-cv-00435-CKK Document 11-3 Filed 05/08/14 Page 1 of 2

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undoubtedly taint the pursuit of justice and at the very least create much more than an
appearance of bias and prejudice.
5. I do not believe there is any way I can receive a fair lawsuit when the judge of my case is in
an emotionally-charged legal battle with my lawyer.

I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed on May 8, 2014.


/s/ Douglas Hamburger
Douglas Hamburger



Case 1:14-cv-00435-CKK Document 11-3 Filed 05/08/14 Page 2 of 2