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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. Klayman1 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

1 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 Kippur2, 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

2 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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