UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

CASE NO. 1:22-cv-24023-SCOLA/GOODMAN

KENNETH C. GRIFFIN,

Plaintiff,

v.

INTERNAL REVENUE SERVICE and U.S. 

DEPARTMENT OF THE TREASURY,

Defendants.

PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO COMPEL DISCOVERY

PURSUANT TO THE COURT’S ADMINISTRATIVE ORDER [ECF 99]

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TABLE OF CONTENTS

I. PRELIMINARY STATEMENT.............................................................................................1

II. ARGUMENT ...........................................................................................................................3

A. Mr. Griffin’s Motion Seeks Information Proportional To The Needs Of 

The Case And Is Minimally Burdensome..................................................................3

B. The Government Fails To Carry Its Burden With Respect To The 

Investigative Files........................................................................................................5

1. The Government Fails To Demonstrate The Applicability Of The 

Investigative Privilege ....................................................................................6

2. Section 6103 Does Not Prohibit Disclosure Of The Investigative 

Files..................................................................................................................8

3. The Privacy Act Does Not Prohibit Disclosure Of The 

Investigative Files ...........................................................................................9

4. The Government Has Waived Privilege Over The Investigative 

Files..................................................................................................................9

III. CONCLUSION ......................................................................................................................10

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TABLE OF AUTHORITIES

Page(s)

Cases

Adult Advoc. & Rep. v. Brookdale Senior Living, Inc.,

2018 WL 1083493 (S.D. Fla. Feb. 27, 2018) (Goodman, J.) ......................................................4

Am. Mod. Select Ins. Co. v. Sutherland,

2013 WL 1767827 (N.D. Ala. Apr. 18, 2013)..............................................................................9

Bautech USA, Inc. v. Resolve Equipment, Inc., 

2024 WL 1929486, at *2 (S.D. Fla. May 2, 2024).....................................................................10

In re Poly. Carpet Antitrust Litig.,

181 F.R.D. 680 (M.D. Ga. 1998)...................................................................................................6

F.TC. v. Timeshare Mega Media & Mktg. Grp., Inc.,

2011 WL 6102676 (S.D. Fla. Dec. 7, 2011).................................................................................6

Kahn v. United States,

2015 WL 3644628 (S.D. Fla. June 10, 2015)...............................................................................6

Manno v. Healthcare Revenue Recovery Grp., LLC,

2012 WL 4192987 (S.D. Fla. Sept. 18, 2012) (Scola, J.) ........................................................2, 3

Statutes & Rules

Fed. R. Civ. P. 26(b)(5)........................................................................................................................9

Other Authorities

DOJ Criminal Tax Manual (2022) ......................................................................................................8

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Mr. Griffin1respectfully submits this reply in further support of his Motion to Compel 

Discovery Pursuant to the Court’s Administrative Order (ECF 111, “Motion”).

I. PRELIMINARY STATEMENT

On April 24, 2024, Mr. Griffin filed his Motion to Compel at the Court’s invitation to

“demonstrate...why the Court should require the Government to resume its document production” 

following Mr. Littlejohn’s deposition. ECF 99 at 2 (emphasis in original). The Motion seeks two

narrow categories of evidence already collected and processed by the Government: first, Mr. 

Littlejohn’s direct “To/From” communications with nine supervisors and coworkers at the IRS, all 

of whom were identified by Mr. Littlejohn during his deposition;

2

and second, materials in the 

Government’s investigative files from its criminal investigation of Mr. Littlejohn. The Motion 

explains in detail why the evidence Mr. Griffin seeks is relevant and necessary to prove his claim 

that the Government unlawfully disclosed his confidential tax information in violation of Section 

7431(a)(1)—a claim that Judge Scola already determined should proceed through discovery when 

he rejected the Government’s motion to stay discovery and motion to dismiss Mr. Griffin’s claim.

In its Opposition (ECF 137, “Opp’n”), the Government offers up a host of red herrings and 

distractions, such as overblown descriptions of its discovery efforts to date and entirely misplaced 

accusations that Mr. Griffin is seeking to “investigate the investigators.” Opp’n at 1. Stripped of 

its bluster, the Opposition rests entirely on spurious claims of burden and unsupported invocations 

of privileges to which the Government is not entitled or simply do not apply.

The Government’s continued efforts to shirk its discovery obligations come as no surprise 

to Mr. Griffin. Since he first brought this action in December 2022, the Government has at every 

1

 Defined terms have the meanings provided in Mr. Griffin’s Motion, ECF 111.

2

 Of the nine IRS employees, two were responsible for directing and supervising 

Mr. Littlejohn’s work, three determined the scope of his access to confidential information, and 

Mr. Littlejohn worked closely with, supervised, and/or trained the other four. See Mot. at 8-9, 19. 

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turn sought to hinder Mr. Griffin’s efforts to pursue his claims through a fair discovery process. 

The Government initially claimed (falsely) that it was “without any clue” as to who could have 

misappropriated Mr. Griffin’s confidential tax return information. When criminal charges were 

filed and it became evident the Government knew all along that it was Mr. Littlejohn that provided 

Mr. Griffin’s confidential information to ProPublica, the Government abdicated its own 

culpability by disavowing and exclusively blaming Mr. Littlejohn while it continued to play the 

same game: dragging its feet for months and producing a total of six publicly available documents, 

raising specious objections to reasonable interrogatories, and blowing through numerous courtordered deadlines without justification or even efforts at meaningful explanation. The 

Government’s Opposition is an unfortunate continuation of the same strategy.

While Mr. Griffin’s Motion is targeted to seek only the most relevant material, the 

Government is withholding these critical documents based on its false assertion that they “have no 

relevance to Plaintiff’s [Section] 7431[(a)(1)]” claim. Opp’n at 5; but see Manno v. Healthcare 

Revenue Recovery Grp., LLC, 2012 WL 4192987, at *3 (S.D. Fla. Sept. 18, 2012) (Scola, J.) 

(“[I]nformation is relevant if it is germane, conceivably helpful to plaintiff, or reasonably 

calculated to lead to admissible evidence.”). This argument is deeply flawed and is addressed at 

length in Mr. Griffin’s Motion. But it is worth noting here that Judge Scola’s Order denying the 

Government’s motion to dismiss Mr. Griffin’s Section 7431(a)(1) claim sets out relevant factors 

that go to establishing Mr. Littlejohn’s status as an IRS employee, including “the IRS’s supervision 

and control of Littlejohn’s work,” and whether the “IRS directly managed the scope and purpose 

of Littlejohn’s daily tasks and projects, making sure he completed his training, monitoring his 

technical performance, controlling his access to IRS data and confidential information, and 

ultimately retaining the authority to reprimand or terminate him.” ECF 108 at 6. There can be no 

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serious argument that Mr. Littlejohn’s communications with his supervisors, close coworkers, and 

colleagues who determined the scope of his work and access to confidential IRS information, or

memoranda of interviews of those individuals and Mr. Littlejohn himself, are not “germane” and 

“conceivably helpful” in the determination of the factors articulated by this Court.

The Government made clear in its response to Mr. Griffin’s Motion what its real problem

is with his discovery requests: the Government does not believe that Mr. Griffin’s claims “have 

merit” and wishes he would instead “sue Mr. Littlejohn.” Opp’n at 1-2. But the Government does 

not get to determine whether Mr. Griffin’s claims have “merit”; the Court does. And the Court

has already determined that Mr. Griffin’s Section 7431(a)(1) claim should proceed. Mr. Griffin 

therefore respectfully asks that the Court hold the Government to its discovery obligations—the 

same obligations that apply to any other litigant in this Court—and order the Government to 

produce the narrow categories of information sought in the Motion.

II. ARGUMENT

A. Mr. Griffin’s Motion Seeks Information Proportional To The Needs Of The 

Case And Is Minimally Burdensome

In asserting that the evidence Mr. Griffin seeks has “no relevance to Plaintiff’s [Section]

7431” claim, Opp’n at 5, the Government misapprehends the applicable standard and fails to meet 

its “burden to demonstrate specifically how the [discovery] request is unreasonable or not 

relevant,” Manno, 2012 WL 4192987, at *3. As detailed in Mr. Griffin’s Motion, the 

Government’s investigative files and the limited set of communications between Mr. Littlejohn 

and his specified IRS colleagues are highly relevant to Mr. Griffin’s theories of liability. Mot. at 

9-11, 18-19. Mr. Littlejohn’s journals, memoranda of interviews with IRS personnel, and specified 

communications would shed light on the fact that “the IRS directly managed the scope and purpose 

of Littlejohn’s daily tasks and projects.” ECF 108 at 6. Given the relevance of these documents, 

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and the “conjoined” nature of proportionality and relevance, Adult Advoc. & Representation v.

Brookdale Senior Living, Inc., 2018 WL 1083493, at *6 (S.D. Fla. Feb. 27, 2018) (Goodman, 

M.J.), the Government’s asserted bases for withholding the evidence should be rejected.

First, the Government asserts that “[n]one of the documents produced support any 

argument that Mr. Littlejohn was an IRS employee,” Opp’n at 7, but this is mere ipse dixit and 

simply wrong: the Government has produced documents that support Mr. Griffin’s claim that Mr. 

Littlejohn was an “employee of the United States.”3 Moreover, memoranda of interviews with 

IRS personnel about Mr. Littlejohn’s duties and responsibilities at the IRS are facially relevant, 

regardless of the Government’s view of its prior production. 

Second, the Government looks to hang its hat on the lack of documents used during

Mr. Littlejohn’s deposition. See, e.g., Opp’n at 8. But whether a document is marked as an exhibit 

in one deposition is obviously neither a fair nor sensible measure of relevance. And it was the 

knowledge gained from reviewing the incomplete set of Mr. Littlejohn’s documents that enabled

Mr. Griffin to elicit testimony from Mr. Littlejohn directly supporting his claim.4 

Finally, the Government’s other chief argument—that it would be burdensome to provide 

communications from nine IRS employees, Opp’n at 10-11—is of no moment. As an initial matter, 

it ignores that Mr. Griffin is simply seeking Mr. Littlejohn’s direct “To/From” communications 

3

 For example, documents show that IRS employees supervised and directed Littlejohn’s 

day-to-day work; that his place of work was at IRS headquarters and other IRS locations; that IRS 

employees treated Mr. Littlejohn interchangeably with other IRS employees; and that Mr. 

Littlejohn regularly did the work of IRS employees by quality checking their work.

4

 Among other things, Mr. Littlejohn testified that: (i) his office was located at IRS 

headquarters; (ii) his direct supervisor was an IRS employee; (iii) the IRS controlled his tasks and 

projects and the scope of his work; (iv) the IRS controlled his access to IRS hardware required to 

do his job as well as his access to confidential tax return information at the IRS; and (v) the IRS 

determined when he would report for work and where and was involved in dictating his time off. 

See ECF 119-1 at 109:20-110:8; 301:1-11, 117:6-9; 312:19-313:3; 93:10-94:3, 319:14-22, 301:1-

11; 105:18-21, 110:15-22; 111: 13-16; 108:1-6.

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with specified employees, which the Government already collected and processed, and which 

would screen out e-mail blasts and other irrelevant materials. There is no need for some “multistep 

process” that begins with the “identification of custodians” and requires an “expansive search” 

that involves “delivering ESI in a usable format outside the agency.” Opp’n at 10-11; ECF 137-4

at ¶ 2. All of this supposedly burdensome work is already complete, and the Government need 

only review documents already collected from Mr. Littlejohn’s files and loaded into a Relativity 

database, see ECF 137-5 ¶ 6—this minimal burden, which any litigant would have to undertake, 

is heavily outweighed by their relevance and Mr. Griffin’s need for the information.5 While the 

Government claims that, as an “example of how burdensome this process has been,” 14 attorneys

spent 118.75 hours over 11 days to review documents (see Opp’n at 10-11; ECF 137-5 ¶ 12)—that

ultimately amounts to 45 minutes per attorney per day, and at that rate, it is no surprise that the 

Government believes it would take 18 months to review a hypothetical 50,000 documents. See id. 

B. The Government Fails To Carry Its Burden With Respect To The 

Investigative Files

Information in TIGTA’s and PIN’s investigative files6—such as memoranda of interviews 

with IRS personnel about Mr. Littlejohn’s duties—is both directly relevant and proportional to the 

needs of this case. See supra at Section II.A. The Government makes no burden argument as to 

these files, and while it raises three different privileges, it fails to establish that any apply. 

5

 In the event that the Court is not inclined to order the Government to produce 

Mr. Littlejohn’s communications with all nine IRS personnel, Mr. Griffin requests that the 

Government provide Mr. Littlejohn’s communications with (i) Paul Wight, (ii) Marsha Coleman, 

(iii) Nanette Downing, (iv) Rene Schwartzman, and (v) Cody Thierry. 

6

 The Government’s asserts that Mr. Griffin “waived the right to dispute the sufficiency 

of PIN’s responses ... and PIN’s privilege log” under Local Rule 26.1(g)(2)(A)(i). Opp’n at 4. 

This is wrong. At the time the Government served these responses and the PIN log, Mr. Griffin 

had already challenged the Government’s assertions of Section 6103 and the investigatory 

privilege, on which the PIN log relied. See ECF 71; ECF 88. 

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1. The Government Fails To Demonstrate The Applicability Of The 

Investigative Privilege

The “proponent of the law-enforcement privilege”—not Mr. Griffin—“bears the ultimate 

burden of demonstrating its applicability.” F.T.C. v. Timeshare Mega Media & Mktg. Grp., Inc., 

2011 WL 6102676, at *4 (S.D. Fla. Dec. 7, 2011). The Government has failed to carry its burden, 

for two reasons: it does not contend that the privilege applies to the material Mr. Griffin seeks, and 

it fails to address the relevant factors courts analyze in assessing this “qualified” privilege.

7

 

First, the Government fails to meet its burden to “demonstrate that the documents contain 

information that the law enforcement privilege is intended to protect.” Kahn v. United States, 2015 

WL 3644628, at *2 (S.D. Fla. June 10, 2015). Indeed, the Government concedes that the privilege 

applies only in two circumstances: where there is an ongoing investigation, and where disclosure 

would “jeopardize future criminal investigations.” Id. As there is no dispute that the 

Government’s investigation has ended, see Mot. at 9, the only question is whether the documents 

at issue would disclose “law enforcement techniques and procedures.” See Fed. Election Comm’n 

v. Rivera, 335 F.R.D. 541, 547 (S.D. Fla. 2020) (Goodman, M.J.). 

Unsurprisingly, the Government fails to argue that the critical information Mr. Griffin is 

seeking—such as Mr. Littlejohn’s electronic journal and memoranda of interviews with IRS 

personnel about their knowledge of Mr. Littlejohn’s duties and responsibilities—would disclose 

such techniques and procedures. That’s because they would not. As to Mr. Littlejohn’s proffer 

memoranda, the Government concedes it waived any privilege that might have existed by showing 

them to Mr. Littlejohn. Mot. at 11 n.17; see also In re Poly. Carpet Antitrust Litig., 181 F.R.D. 

7

 The Government suggests that Mr. Griffin could have “question[ed] Mr. Littlejohn about 

the entries in the journal during his deposition.” Opp’n at 16. The Government omits that it failed 

to produce, log, or otherwise disclose the existence of Mr. Littlejohn’s journal, leaving Mr. Griffin 

to discover its existence during Mr. Littlejohn’s deposition. 

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680, 689 (M.D. Ga. 1998) (noting that “the law enforcement investigatory privilege ‘can be 

waived, and, once waived, is lost’”). The Government is required to establish that the law 

enforcement privilege applies on a document-by-document basis, Mot. at 14, and its blanket 

statements about applicability fail to satisfy its burden, Opp’n at 11-13. 

Second, balancing “the interests of the litigant seeking the information against the 

government’s interest in nondisclosure,” shows that the “qualified privilege” should give way here.

See Rivera, 335 F.R.D. at 548; see also Mot. at 15. “[T]he importance of the information sought”

and the nature of the information as “factual data” rather than “evaluative summary,” weigh

strongly in favor of disclosure. See Rivera, 335 F.R.D. at 547-48. Indeed, “[m]any of the concerns 

typically underlying law enforcement privilege claims are inapplicable here” where there is no 

“confidential informant” or “confidential law enforcement strategies which would be revealed” by 

the disclosure of the investigative file. See id. (“The ‘technique’ involved here—interviewing fact 

witnesses and writing a report summarizing what the witness said—is hardly confidential.”). The 

Government makes no argument to the contrary.

Instead, the Opposition relies on a declaration from TIGTA to suggest that if the entire

investigative file is disclosed, at least some materials that are “generally included” in a TIGTA 

investigative file “could reasonably be expected to risk circumvention of the law.” ECF 137-3 

¶¶ 5 & 8. But it is the Government’s burden to then identify those specific documents, Mot. at 14, 

and it fails to demonstrate that any specific document in the investigative files would “serve as a 

roadmap for circumventing IRS and TIGTA controls.” ECF 137-3 at ¶ 9. Indeed, it is undisputed 

there are materials in the investigative files that have no meaningful bearing on monitoring systems 

at the IRS that ostensibly exist or the Government’s investigative techniques (e.g., Mr. Littlejohn’s 

communications with ProPublica, Mr. Littlejohn’s electronic journal, etc.).

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2. Section 6103 Does Not Prohibit Disclosure Of The Investigative Files

Section 6103 does not apply to the investigative files for two independent reasons: (i) the 

information was collected as part of a DOJ investigation and (ii) disclosure here falls under the 

statutory exception of Section 6103(h)(4). Mot. at 13-14. 

The Government concedes that information collected by PIN (even with the assistance of 

TIGTA) under the DOJ’s authority “is not protected by [Section] 6103,”

8

and it ignores Mr. 

Littlejohn’s testimony that it was the Department of Justice and no longer TIGTA that was leading

the criminal investigation as early as December 2021 when he was served a Grand Jury subpoena.

9

Although TIGTA has authority to conduct investigations of violations under Title 26 on its own, 

the Department of Justice’s Criminal Tax Manual makes clear that TIGTA’s investigative 

authority ended once PIN became involved and opened an grand jury investigation, and served a

grand jury subpoena on Mr. Littlejohn.10 Consequently, materials collected in or after December 

2021—when DOJ/PIN became involved—were not “furnished to, or collected by the Secretary” 

of the Treasury, and thus are not “return information” under Section 6103. See Mot. at 13-14.

The Court need not reach this issue, however, because Section 6103(h)(4)(A) permits 

disclosure of return information “in a Federal or State judicial or administrative proceeding 

pertaining to tax administration”—such as this one—if “the proceeding arose out of, or in 

connection with, determining the taxpayer’s civil or criminal liability” under Title 26, as 

Mr. Griffin’s claims do. See ECF 88. The Government continues to have no meaningful response 

8

 See Opp’n at 12; see also Mot. at 13-14.

9

 See ECF 119-1 at 239:2-13, 249:21-250:2, 294:11-295:19. 

10

 See Criminal Tax Manual, Section 1.03 (“Before a case is referred to the Department 

of Justice, the IRS has authority to investigate using its administrative summons power. That 

power terminates when the Secretary of the Treasury has recommended that the Attorney General 

prosecute or conduct a grand jury investigation of a person for an offense connected with the 

administration of the internal revenue laws. 26 U.S.C. § 7602(d)(A)(I).”).

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to Section 6103(h)(4)(A)’s statutory exception, and does not even mention it in its Opposition. 

3. The Privacy Act Does Not Prohibit Disclosure Of The Investigative 

Files

The Government does not dispute that this Court may order the disclosure of materials 

protected by the Privacy Act. Opp’n at 17. Instead, it argues that (i) “nothing [Mr. Griffin] seeks 

from PIN is relevant to his § 7431(a)(1) claim,” (ii) “the harm to Mr. Littlejohn is tangible,” and 

(iii) disclosure should be under the Protective Order. Id. at 17-19. These arguments are strawmen.

As an initial matter, the relevance of the PIN file—which includes proffer memoranda and 

Mr. Littlejohn’s grand jury testimony about the unlawful disclosures—is described in detail in Mr. 

Griffin’s Motion and above. Mot. at 10-11. Moreover, the Opposition fails to identify any harm

to Mr. Littlejohn, nor could it, likely because there is no cognizable harm here. Indeed, 

Mr. Littlejohn himself stated in his deposition that he “wanted to come clean, take responsibility 

for [his] actions,”11 and he declined to designate any of his testimony or production as confidential, 

demonstrating that he does not share the Government’s supposed concern about potential harm. 

Second, Mr. Littlejohn already pled guilty to his offense, and while the Government asserts that 

an appeal is pending, none of the issues on appeal appear related to the merits of this case. Finally, 

courts permit disclosure under the Privacy Act when potential harm can be mitigated by, among 

other things, marking documents as “confidential,” see Am. Mod. Select Ins. Co. v. Sutherland, 

2013 WL 1767827, at *3 (N.D. Ala. Apr. 18, 2013), just as the information would be here. 

4. The Government Has Waived Privilege Over The Investigative Files

The Government’s privilege logs must “describe the nature of the documents” sufficiently 

to “enable other parties to assess the claim.” See Fed. R. Civ. P. 26(b)(5). But here, the 

Government identified authors of communications as “various” and included a single entry for the 

11

 ECF 119-1 at 256:8-9. 

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entire “TIGTA investigative file.” Mot. at 11-12. To the extent that the Government has taken 

issue with the fact that Mr. Griffin seeks the “entire” investigative files, he of course seeks only 

the relevant documents therein. Given the Government’s facially insufficient privilege logs—

indeed, the Opposition reveals for the very first time that the investigative files contain “thousands” 

of documents while the TIGTA and PIN privilege logs have a combined 14 entries—Mr. Griffin 

has no information at this point to determine the full scope of what is relevant in those files. 

The Government now argues, only in a footnote, that “[m]ore detailed logs run[] the risk 

of disclosing information protected under [Section] 6103 and the law enforcement investigatory 

privilege” and “would impose a significant burden on TIGTA and PIN to log with specificity

thousands of irrelevant and non-responsive records contained in their files.” Opp’n at 11 n.3. This 

is, of course, not true; irrelevant and non-responsive documents need not be logged. But the 

Government already conceded that it is required to, and represented that it would, log responsive 

materials allegedly protected by Section 6103. See ECF 70 at 5. The Government made that 

concession because the law so requires, see ECF 71 at 5-6, and because this Court ordered the 

Government to log those materials, ECF 84. A finding of waiver is particularly appropriate where 

the non-producing party has suffered “prejudice that the Local Rules are specifically designed to 

avoid,” given that the Local Rules are designed “to surface disputes over privilege early in the 

discovery period in order to give the parties (and, if necessary, the Court) time to resolve them.” 

Bautech USA, Inc. v. Resolve Equipment, Inc., 2024 WL 1929486, at *2 (S.D. Fla. May 2, 2024). 

With discovery set to close in a month, and the Government having still failed to provide a 

sufficient privilege log, the Government has waived any protection over items in its investigative 

files. 

III. CONCLUSION

For the foregoing reasons, the Court should grant the relief sought in Mr. Griffin’s Motion. 

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Dated: May 10, 2024 Respectfully submitted,

 By: /s/ Jason D. Sternberg

 William A. Burck (pro hac vice)

 Derek L. Shaffer (pro hac vice)

 Alexander J. Merton (pro hac vice)

QUINN EMANUEL URQUHART & SULLIVAN LLP

1300 I Street, N.W., Suite 900

Washington, DC 20005

(202) 538-8334 

williamburck@quinnemanuel.com

derekshaffer@quinnemanuel.com

ajmerton@quinnemanuel.com

John F. Bash (pro hac vice)

QUINN EMANUEL URQUHART & SULLIVAN LLP

300 West 6th St, Suite 2010

Austin, TX 78701

(737) 667-6100

johnbash@quinnemanuel.com

Jason D. Sternberg (Florida Bar No. 72887)

QUINN EMANUEL URQUHART & SULLIVAN LLP

2601 South Bayshore Dr, Suite 1550

Miami, FL 33133

(305) 402-4880

jasonsternberg@quinnemanuel.com

Christopher D. Kercher (pro hac vice)

Peter H. Fountain (pro hac vice)

QUINN EMANUEL URQUHART & SULLIVAN LLP

51 Madison Avenue, 22nd Floor,

New York, New York 10010

(212) 849-7000 

christopherkercher@quinnemanuel.com

peterfountain@quinnemanuel.com

Counsel to Plaintiff Kenneth C. Griffin

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on this 10th day of May, 2024, I caused a copy of the foregoing 

document to be filed with the Clerk of Court using the CM/ECF electronic filing system, which 

will send notification to all counsel of record.

By: /s/ Jason D. Sternberg

Jason D. Sternberg

Fla. Bar No. 72887

jasonsternberg@quinnemanuel.com 

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