UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 1:20-CV-21254-BLOOM/LOUIS

SECURITIES AND EXCHANGE 

COMMISSION,

Plaintiff,

v.

JUSTIN W. KEENER D/B/A JMJ FINANCIAL,

Defendant.

DECLARATION OF VEENA VISWANATHA IN SUPPORT OF DEFENDANT JUSTIN 

KEENER D/B/A JMJ FINANCIAL’S MOTION TO COMPEL COMMUNICATIONS 

BETWEEN THE SEC’S OFFICE OF INTERPRETATION AND GUIDANCE AND 

THIRD PARTIES

I, Veena Viswanatha, declare as follows: 

1. I am an attorney duly admitted to practice before this Court. I am a partner with 

Buckley LLP, co-counsel of record for Defendant Justin Keener d/b/a JMJ Financial (“Mr. 

Keener”). I have personal knowledge of the facts stated in this declaration. If called as a 

witness, I could and would testify competently to each fact. I make this declaration in support of 

Mr. Keener’s Motion to Compel Communications Between the SEC’s Office of Interpretation 

and Guidance and Third Parties (the “Motion”). 

2. Attached hereto as Exhibit 1 is a true and correct copy of Defendant’s First Set of 

Interrogatories to Plaintiff, dated December 23, 2020. 

3. Attached hereto as Exhibit 2 is a true and correct copy of Defendant’s Second Set 

of Requests for Production of Documents, dated March 19, 2021. 

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4. Attached hereto as Exhibit 3 is a true and correct copy of the SEC’s Guide to 

Broker-Dealer Registration. It is available at https://www.sec.gov/reportspubs/investorpublications/divisionsmarketregbdguidehtm.html and was accessed and printed on July 1, 2021. 

5. Attached hereto as Exhibit 4 is a true and correct copy of a May 11, 2021 letter 

from Joshua Braunstein and Antony Petrilla, counsel for SEC, to Christopher Regan and Veena 

Viswanatha, counsel for Mr. Keener. 

6. Attached hereto as Exhibit 5 is a true and correct copy of an April 30, 2021 email 

from Joshua Braunstein, counsel for SEC, to Christopher Regan, Benjamin Greenberg, and 

Olivia Rauh, counsel for Mr. Keener. 

7. Attached hereto as Exhibit 6 is a true and correct copy of a May 3, 2021 email 

from Veena Viswanatha, counsel for Mr. Keener, to Joshua Braunstein and Antony Petrilla, 

counsel for SEC. 

8. Attached hereto as Exhibit 7 is a true and correct copy of a June 28, 2021 email 

from Veena Viswanatha, counsel for Mr. Keener, to Joshua Braunstein and Antony Petrilla, 

counsel for SEC. 

9. Attached hereto as Exhibit 8 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-13, which was contained in the SEC’s June 25, 2021 production. 

10. Attached hereto as Exhibit 9 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-51, which was contained in the SEC’s June 25, 2021 production.

11. Attached hereto as Exhibit 10 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-53, which was contained in the SEC’s June 25, 2021 production.

12. Attached hereto as Exhibit 11 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-02, which was contained in the SEC’s June 25, 2021 production.

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13. Attached hereto as Exhibit 12 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-59, which was contained in the SEC’s June 25, 2021 production. 

14. Attached hereto as Exhibit 13 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-62, which was contained in the SEC’s June 25, 2021 production. 

15. Attached hereto as Exhibit 14 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-44, which was contained in the SEC’s June 25, 2021 production. 

16. Attached hereto as Exhibit 15 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-50, which was contained in the SEC’s June 25, 2021 production. 

17. Attached hereto as Exhibit 16 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-63, which was contained in the SEC’s June 25, 2021 production.

18. Attached hereto as Exhibit 17 is a true and correct copy of a June 21, 2021 email 

from Christopher Regan, counsel for Mr. Keener, to Joshua Braunstein and Antony Petrilla, 

counsel for SEC. 

19. Attached hereto as Exhibit 18 is a true and correct copy of a June 25, 2021 email 

from Antony Petrilla, counsel for SEC, to Christopher Regan, counsel for Mr. Keener. 

20. Attached hereto as Exhibit 19 is a true and correct copy of a document bearing the 

Bates label SEC-JMJ-OIG-13 - SEC-JMJ-OIG-31, which was contained in the SEC’s June 25, 

2021 production. 

21. Attached hereto as Exhibit 20 is a true and correct copy of a transcript of the April 

6, 2021 hearing held in SEC v. Ripple Labs, Inc., No. 20 Civ. 10832 (S.D.N.Y. Apr. 6, 2021). 

22. Attached hereto as Exhibit 21 is a true and correct copy of a May 6, 2021 letter 

from Joshua Braunstein and Antony Petrilla, counsel for SEC, to Christopher Regan and Veena 

Viswanatha, counsel for Mr. Keener. 

Case 1:20-cv-21254-BB Document 47-1 Entered on FLSD Docket 07/02/2021 Page 3 of 4
23. Attached hereto as Exhibit 22 is a true and correct copy of a June 21, 2021 email 

from Joshua Braunstein, counsel for SEC, to Christopher Regan, counsel for Mr. Keener. 

24. Attached hereto as Exhibit 23 is a true and correct copy of a June 21, 2021 email 

from Christopher Regan, counsel for Mr. Keener, to Joshua Braunstein and Antony Petrilla, 

counsel for SEC. 

I declare under the penalty of perjury that the foregoing is true and correct. 

Dated this 2nd day of July, 2021. 

Veena Viswanatha

BUCKLEY LLP

2001 M Street NW, Suite 500 

Washington, DC 20036 

Telephone: (202) 349-8000 

Facsimile: (202) 349-8080 

vviswanatha@buckleyfirm.com

Counsel for Defendant Justin W. Keener 

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