UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

KENNETH C. GRIFFIN,

 Plaintiff,

 v.

INTERNAL REVENUE SERVICE and U.S.

DEPARTMENT OF THE TREASURY,

 Defendants.

Case No. 1:22-cv-24023-Scola/Goodman

JOINT MOTION TO EXTEND RESPONSE DEADLINES RELATED TO

DEFENDANT’S MOTION TO DISMISS

The parties in the above captioned action (collectively, “Parties”), by and through their

undersigned counsel and pursuant to Rule 6(b)(1)(A) of the Federal Rules of Civil Procedure,

respectfully move this Court to extend the current response deadlines related to Defendant’s

motion to dismiss from May 9, 2023 (Plaintiff’s Opposition Brief) and May 16, 2023 (Defendant’s

Reply Brief) to May 26, 2023 and June 21, 2023, respectively.

1. Plaintiff commenced this action on December 13, 2022. (ECF No. 1.) On March 8,

2023, Defendant moved for a forty-five day extension of time to respond to Plaintiff’s complaint,

which Plaintiff did not oppose. (ECF No. 21.) The Court granted that motion on March 9, 2023.

(ECF No. 22.) On April 26, 2023, Defendant moved to dismiss Plaintiff’s complaint. (ECF No.

23.)

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2. Pursuant to Local Rule 7.1(c)(1), Plaintiff’s response to the motion to dismiss is

currently due on May 9, 2023, and Defendant’s reply in support of the motion to dismiss is

currently due on May 16, 2023.

3. Good cause exists to extend the current response deadlines related to the pending

motion to dismiss from May 9, 2023 (Plaintiff’s Response Deadline) and May 16, 2023

(Defendant’s Reply Deadline) to May 26, 2023 and June 21, 2023, respectively, because the

additional time will provide the Parties opportunities to gather additional information necessary to

prepare their responsive pleadings and both Parties would benefit from the additional time.

4. Therefore, in light of the foregoing and pursuant to their agreement, the Parties

respectfully request that this Court enter an order resetting the current deadlines as follows:

a. Plaintiff may file his opposition to the motion to dismiss on or before May 26,

2023; and

b. Defendant may file a reply in support of the motion to dismiss on or before June

21, 2023.

5. This joint motion is made in good faith and not for purposes of delay, and this Court

has not previously modified or extended the deadlines for the response and reply to the pending

motion to dismiss.

WHEREFORE, for the foregoing reasons, the Parties respectfully request that the Court

grant this joint motion and enter the motion to dismiss briefing schedule provided above. A

proposed order granting this joint motion is attached as Exhibit A.

Case 1:22-cv-24023-RNS Document 26 Entered on FLSD Docket 05/03/2023 Page 2 of 4
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Date: May 3, 2023 Respectfully Submitted,

For Plaintiff

By: /s/ Jason D. Sternberg

William A. Burck (admitted pro hac vice)

Derek L. Shaffer (admitted pro hac vice)

Alexander J. Merton (admitted 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

Christopher D. Kercher (admitted pro hac vice)

QUINN EMANUEL URQUHART & SULLIVAN, LLP

51 Madison Avenue, 22nd Floor

New York, New York 10010

(212) 849-7000

christopherkercher@quinnemanuel.com

John F. Bash, III (admitted 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 Drive, Suite 1550

Miami, FL 33133

(786) 850 3607

jasonsternberg@quinnemanuel.com

For Defendant

DAVID A. HUBBERT

Deputy Assistant Attorney General

By: /s/ Zachary A. Gray

 Elizabeth N. Duncan

ELIZABETH N. DUNCAN

Virginia Bar No. 90685

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ZACHARY A. GRAY

California Bar No. 291376

STEPHANIE A. SASARAK

Maryland Bar No. 1012160096

Trial Attorneys, Tax Division

U.S. Department of Justice

P.O. Box 14198

Washington, D.C. 20044

202-514-6546 (v) | 202-514-4963 (f)

Elizabeth.N.Duncan@usdoj.gov

Zachary.A.Gray@usdoj.gov

Stephanie.A.Sasarak@usdoj.gov

Of counsel:

MARKENZY LAPOINTE

United States Attorney

Southern District of Florida

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on this 3rd day of May, 2023, 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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