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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.

EXPEDITED NOTICE OF HEARING (VIA ZOOM)

PLEASE TAKE NOTICE that a hearing on discovery matters will be held before 

Magistrate Judge Jonathan Goodman on June 20, 2024 at 2:30 PM via Zoom. The discovery 

matters to be heard include:

1. Whether Defendants’ objections to Plaintiff’s Rule 30(b)(6) deposition notice should be

overruled. The specific objections at issue1are:

a. Whether, for Topics A and B, the Government is required to produce a designee to 

testify about all contracts between Booz Allen Hamilton and the IRS that Mr. 

Littlejohn worked on, or can refuse to produce a designee to testify about contracts 

Mr. Littlejohn worked on that the Government has deemed “irrelevant”; 

1

 While the Government asserted additional objections to the Rule 30(b)(6) deposition 

topics, counsel for Plaintiff understands that the Government is not refusing testimony on the basis 

of those objections (and that they are therefore akin to general objections). This Notice of Hearing 

therefore identifies the Government’s substantive objections to the noticed deposition topics. 

Case 1:22-cv-24023-RNS Document 166 Entered on FLSD Docket 06/13/2024 Page 1 of 5
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b. Whether, for Topic C, the Government is required to produce a designee to testify 

regarding the IRS’s responses to publicly available TIGTA and GAO reports 

detailing security deficiencies at the IRS;

c. Whether, for Topic D, the Government can refuse, on relevancy and privilege 

grounds, to produce a designee to testify about the processes or mechanisms by 

which Mr. Littlejohn was able to unlawfully obtain return information, and when 

and how the United States learned of Mr. Littlejohn’s misappropriation of return 

information;

d. Whether the Government can refuse to produce a designee to testify about Topic 

F(1) and (2), on the grounds that the allegations in the Second Amended Complaint 

is not a sufficiently detailed topic and that the date of TIGTA’s referral of its 

investigation to PIN is not relevant.

Copies of the relevant source documents will be emailed to Chambers consistent with the 

procedures set forth in Magistrate Judge Goodman’s Discovery Procedures Order. See ECF 16 

at 4. 

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CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(a)(3)

Undersigned counsel conferred with counsel for Defendants by phone on June 12, 2024 in 

a good-faith effort to resolve by agreement the issues raised herein, but were unable to reach any 

resolution of the issues.

Dated: June 13, 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

Case 1:22-cv-24023-RNS Document 166 Entered on FLSD Docket 06/13/2024 Page 3 of 5
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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

Case 1:22-cv-24023-RNS Document 166 Entered on FLSD Docket 06/13/2024 Page 4 of 5
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on this 13th day of June, 2024, I filed a copy of the foregoing 

document 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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