IN THE UNITED STATES DISTRICT COURT 

 FOR THE SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

Case No. 1:22-cv-24023-SCOLA/GOODMAN 

KENNETH C. GRIFFIN, 

 Plaintiff, 

 v. 

INTERNAL REVENUE SERVICE, et al., 

 Defendants. 

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DEFENDANTS’ RESPONSE IN OPPOSITION TO PLAINTIFF’S MOTION TO 

MODIFY THE SCHEDULING ORDER

 On December 12, 2023, the Court granted Plaintiff’s unopposed motion to amend the 

scheduling order and set a new fact discovery deadline of June 10, 2024. (ECF No. 75). The 

Court noted that “the extensions requested are substantial” but granted it because “importantly, 

the parties are in agreement.” The Court “forewarned that any further extensions are unlikely 

to be granted absent particularly extenuating circumstances.” (Id. (emphasis in the 

original)). Plaintiff has now moved again seeking another 90 days to take fact discovery “for 

good cause shown.” Plaintiff’s motion fails to establish good cause, let alone demonstrate 

“particularly extenuating circumstances” for a 90-day extension. And, importantly, the parties 

are not in agreement that an extension is necessary. Indeed, the United States opposes a further 

extension of discovery, which, if granted, rewards Plaintiff’s lack of diligence in taking 

discovery within the time the Court afforded him to demonstrate that his wrongful disclosure 

claim falls within the waiver of sovereign immunity under section 7431(a)(1) of the Internal 

Revenue Code. 

 

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INTRODUCTION 

Discovery in this case has been contentious. The United States wishes to move past these 

disputes and the exaggerated rhetoric and advance this case toward resolution. But it takes two to 

tango, and Plaintiff refuses to dance, choosing to shout “stonewalling” rather than move to the 

music of cooperation. 

The discovery produced to date paints a different picture than stonewalling. Since 

Plaintiff filed his Second Amended Complaint in November 2023, the United States has 

responded to 93 requests for production, 109 requests for admission, and 21 interrogatories and 

produced thousands of documents, over 44,000 pages, all of which identify persons who may 

have knowledge relevant to Plaintiff’s claim. The United States also ensured that Charles 

Littlejohn, the contractor who disclosed Plaintiff’s return information to ProPublica, received a 

testimonial authorization and release of non-disclosure agreements from the IRS so that he could 

testify freely at his deposition. 

Plaintiff has done nothing with the troves of information provided by the United States to 

advance his case until May 15, 2024. On that date, with less than 30 days remaining in discovery 

and without coordinating on the availability of Government counsel or any witnesses, Plaintiff 

noticed the depositions of 8 individuals (7 current and former IRS employees and a reporter from 

ProPublica who are located throughout the country) for the last two weeks of discovery. Two 

days later, Plaintiff served a single, improper Rule 30(b)(6) notice of deposition seeking 

testimony from two separate government agencies and has yet to confer on his proposed 67 

topics. All told, with less than 30 days in discovery, Plaintiff notified the United States of his 

intent to take 9 depositions during the last two weeks of discovery, including on weekends. As of 

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the filing of this response, only 4 of the IRS deponents have been served with a subpoena 

commanding their attendance. 

The United States understands Plaintiff’s desire to take depositions he believes are 

necessary and offered to facilitate the scheduling difficulties caused by his late notice. But the 

United States does not understand why Plaintiff failed to take any action to depose the known 

individuals earlier. Perhaps Plaintiff believes he needed additional documents to take these 

depositions. If so, it made little sense for Plaintiff to wait more than 7 weeks after Littlejohn’s 

deposition to file his motion to compel additional discovery. And it is particularly egregious for 

Plaintiff to claim he needs an additional three months to investigate his claims when the court (1) 

made clear that any motion to compel must be limited to discovery of leads Littlejohn’s 

testimony provided; and (2) set a deadline of May 29, 2024 for the government to provide 

additional discovery in response to that motion. The United States’ production on that date will 

leave Plaintiff with ample time to conduct the depositions that it noticed. 

When the hyperbole and aspersions are trimmed from Plaintiff’s argument, it is apparent 

that Plaintiff’s purported need for an extension is a problem of his own making. And it is a 

problem that he compounded when he rejected the United States’ proposal of an 18-day 

extension of discovery for the limited purpose of taking depositions on dates and at locations that 

are agreeable to the parties and witnesses. Plaintiff’s lack of diligence and cooperation should 

not be rewarded with another extension of discovery that upends the waiver of sovereign 

immunity found in section 7431(a). 

ARGUMENT 

Following the identification and prosecution of Charles Edward Littlejohn, an IRS 

contractor employed by Booz Allen Hamilton (BAH), as the individual who disclosed his return 

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information in violation of § 6103 of the Internal Revenue Code (26 U.S.C.), Plaintiff filed a 

two-claim amended complaint for damages against the United States under 26 U.S.C. 7431(a)(1), 

and the Privacy Act. (ECF No. 55). The Privacy Act claim has been dismissed. (ECF No. 108). 

What remains is a single claim under § 7431(a)(1) seeking to hold the United States liable for 

Littlejohn’s unlawful disclosure of Plaintiff’s return information under § 7431(a)(1).1 

The parties have engaged in extensive written discovery on Plaintiff’s contention that 

Littlejohn should be considered a government employee under § 7431. In an effort to shoehorn 

his claim into § 7431(a)(1) (rather than § 7431(a)(2)), Plaintiff deposed the Littlejohn for 

approximately 6 hours on March 19, noticed depositions of 7 IRS personnel with whom 

Littlejohn interacted for May 31 – June 7, and served a notice to take a Rule 30(b)(6) notice of 

the IRS on June 10, which is the last day permitted for discovery under the current schedule. A 

90-day extension for further discovery on the § 7431 claim is neither necessary nor justified by 

particularly extenuating circumstances. 

I. Extending fact discovery for 90 days is unnecessary.

Discovery has been open for over a year and already extended once. From the beginning 

of this case, the United States has asserted that it has not waived sovereign immunity and thus 

the Court lacks jurisdiction to grant the relief Plaintiff seeks. Plaintiff’s primary claim is that a 

non-employee contractor should be treated as a de facto employee of the United States for 

purposes of § 7431(a)(1)’s waiver of sovereign immunity. That claim is unsupported by the plain 

language of the statute. Similarly, Plaintiff’s “alternative theories” fall outside § 7431(a)(1)’s 

1

 Recognizing that Littlejohn was employed by Booz Allen Hamilton, another taxpayer whose 

return information Littlejohn disclosed to ProPublica recently filed a complaint against BAH 

under § 7431(a)(2) as the contracting entity responsible for his violation of § 6103. See Kelcy L. 

Warren v. Booz Allen Hamilton, Inc., Dkt. No. 8:24-cv-01252-LKG (D. Md.). 

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sovereign immunity waiver. We are not asking the Court to adjudicate these issues on this 

procedural motion but raise them to illustrate the lack of good cause to grant the extension 

Plaintiff seeks. Discovery is nearly complete, with depositions the only remaining task. 

Additionally, an extension will force the United States to continue to devote limited resources 

responding to Plaintiff’s discovery that goes far beyond any limited fact-finding to determine if 

his claim fits within § 7431(a)(1)’s waiver of sovereign immunity. 

A. Discovery on Plaintiff’s theory and alternative theories is largely complete.

 Section 7431(a)(1) waives sovereign immunity for a taxpayer to seek damages against the 

United States if (1) an officer or employee of the United States; (2) knowingly or negligently; (3) 

inspects or discloses; (4) return or return information; (5) in violation of 26 U.S.C. § 6103. The 

facts necessary to determine if § 7431(a)(1)’s waiver of sovereign immunity applies are known 

and undisputed. Littlejohn, who was not and has never been an officer or employee of the United 

States, knowingly disclosed Plaintiff’s return or return information in violation of § 6103. (ECF 

No. 119-1 (Littlejohn Depo. Tr.) at 308:7 – 308:14). And yet, Plaintiff argues that Littlejohn was 

“effectively an employee” based on factors Plaintiff alleges he uncovered in Littlejohn’s 

testimony.(ECF No. 138 at 8). 

We disagree with Plaintiff’s description of Littlejohn’s testimony and his interpretation of 

§ 7431(a)(1) as a waiver of sovereign immunity with pliable boundaries. That interpretation flies 

in the fact of black letter law that waivers of sovereign immunity must be narrowly and strictly 

construed. Foster Logging, Inc. v. United States, 973 F.3d 1152, 1157 (11th Cir. 2020). That is, 

of course, a pure question of law for the Court to resolve at the appropriate time. What is truly 

remarkable in the present context, is Plaintiff’s claim that he needs an additional 90 days of 

discovery even though he has twice represented to this Court that he believes the facts already 

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show Littlejohn was a “de facto” or “effectively” and employee of the IRS. (See id., and ECF 

No. 111 at 10 (“Mr. Littlejohn’s deposition testimony also provided critical evidence that he 

functioned as a de facto employee . . .”)). Plaintiff’s statement that he possesses facts to prove his 

theory undercuts his need for additional discovery beyond what he already scheduled. 

When, as here, the parties do not dispute the facts, just the legal consequences of those 

facts, the matter is ripe for summary judgment. Indeed, based on all the materials Plaintiff has 

submitted with his various discovery motions, the Court has all the facts necessary to determine 

if Littlejohn an “employee of the United States” so that Plaintiff may bring his claim against the 

United States under § 7431(a)(1).

 Just as Plaintiff’s primary claim does not warrant an extension of discovery, neither do 

his “alternative theories.” The Court has already expressed doubt regarding the viability of his 

claims that the United States is liable to him under § 7431(a)(1) because the IRS provided too 

much access to Littlejohn and because the IRS failed to prevent Littlejohn’s criminal conduct by 

not “safeguarding” return or return information. (ECF No. 108 at 8.) Plaintiff’s response (ECF 

No. 133 ) to the Court’s order to show cause simply affirms the Court’s skepticism. If, as 

Plaintiff contends, the IRS violated § 6103 by granting Littlejohn more access than he needed to 

perform his duties or failing install safeguards, there would have been no reason for Congress to 

expand § 7431 to include claims for wrongful inspection when it enacted the Taxpayer Browsing 

Protection Act in 1997. Pub. L. 105–35, 111 Stat. 104. Whether one has access to return 

information under § 6103(h)(1) (which permits IRS employees to inspect return information in 

connection with their official duties) or § 6103(n) (which authorized Littlejohn to obtain return 

information), § 6103(a) requires both to maintain the confidentiality of that information. And 

§ 7431(a)(1) and (a)(2) provide civil remedies when they don’t. Here, Littlejohn violated 

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§ 6103(a) by disclosing return information to ProPublica. There is nothing in § 7431 that creates 

a cause of action— or extends liability—for failing to prevent Littlejohn from abusing his 

position to advance his illicit purpose. Welborn v Internal Revenue Serv., 218 F. Supp. 3d 64, 81 

(D.D.C. 2016) (United States had sovereign immunity from taxpayer’s claim that the IRS 

negligently disclosed return information by failing to safeguard such information; taxpayers 

conflate a failure to safeguard claim under the Privacy Act with a disclosure claim under the 

Internal Revenue Code and extend the Code to a cause of action for which sovereign immunity 

had not been waived). 

Even assuming there are additional facts that Plaintiff may yet uncover, the only 

discovery that remains to be complete are depositions. The United States has produced thousands 

of documents, responded to 109 requests for admission, answered 21 interrogatories that 

included dozens of compound parts, and will make a final production on May 29, 2024. And 

BAH produced thousands of documents in response to Plaintiff’s subpoena. Given that written 

discovery will soon be complete, Plaintiff has not shown good cause, let alone “particularly 

extenuating circumstances” to extend the deadlines by 90 days. 

B. Additional discovery runs counter to the doctrine of sovereign immunity.

The doctrine of sovereign immunity is a fundamental tenet of our legal system. The 

United States cannot be sued without its express consent. United States v. Mitchell, 445 U.S. 

535, 538 (1980). As discussed above, the United States’ waiver of sovereign immunity under § 

7431(a)(1) is limited to unauthorized disclosures of return information by officers of employees 

of the United States. This statute does not define what an officer or employee of the United 

States is. But it does not have to because Congress expressly provided a remedy for when a 

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person other than officer or employee of the United States discloses return information in 

violation of § 6103. The taxpayer’s remedy is to sue that person under 26 U.S.C. § 7431(a)(2). 

The United States understands that the Court found it needed some additional factual 

development to answer the question of whether Littlejohn can be considered an employee of the 

United States. Although it disputes that any discovery was needed, the United States has gone to 

great lengths as detailed in this response to respond to Plaintiff’s discovery. Indeed, the United 

States’ efforts have gone far beyond the limited factual development needed to resolve the 

sovereign immunity question. Additional time on discovery on this matter will force the United 

States to expend significant resources on a suit that this Court may not even have jurisdiction to 

entertain. That is precisely why sovereign immunity exists—to preserve the resources of the 

Government (taxpayer funds) from being spent on claims that Congress did not allow. Cook v. 

Taylor, No. 18-977, 2019 WL 1233853, at *1 (M.D. Ala. Mar. 15, 2019) (“[S]overeign 

immunity presents a special concern that a party raising the defense should not be subjected to 

the burdens of litigation before the defense has been decided.”) (citing Bouchard Transp. Co. v. 

Fla. Dep’t of Env’t Prot., 91 F.3d 1445, 1448 (11th Cir. 1996)). 

To be clear, the discovery to date is more than enough to determine if Littlejohn is an 

“employee of the United States” within the meaning of § 7431. If he is, Mr. Griffin is entitled to 

the statutory damages his Amended Complaint requests and this case is over. Otherwise, his 

remaining claim should be dismissed. There is no need for a 90 day extension of all case 

deadlines to reach either point. 

II. Plaintiff lacked diligence pursuing its claim. 

A scheduling order will not be disturbed for good cause if a party cannot demonstrate it 

was diligent in pursuing its claims. Sosa v. Airprint Sys., Inc. 133 F.3d 1417, 1418 (11th Cir. 

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1998). While the United States has gone to tremendous efforts to respond to extensive discovery 

requests over a short period, Plaintiff has not demonstrated diligence in timely pursuing 

discovery. The Court should deny Plaintiff’s request to extend discovery by 90 days for a lack of 

good cause. 

A. The United States has not “stonewalled” discovery.

Plaintiff’s recent filings echo the refrain that the United States has “stonewalled” his 

discovery efforts. (ECF Nos. 111 at 7, 22, 138 at 5-7, 11-12.). Not so. The United States 

understands that Plaintiff is a victim of Littlejohn’s disclosure of his confidential return 

information to ProPublica and that he seeks to vindicate his rights. But the United States has 

vindicated Plaintiff’s rights (and the rights of all other victims of Littlejohn’s conduct) when it 

asked that Littlejohn be sentenced to a five-year prison term—the maximum punishment allowed 

by law. Plaintiff’s accusations that the United States has somehow stonewalled discovery in this 

civil action does not align with reality. The United States has responded to hundreds of discovery 

requests and produced over 44,000 pages of documents, with additional pages to be produced 

May 29. From these responses and Littlejohn’s deposition, Plaintiff has all the information he 

needs. To the extent he requires 90 days to take additional depositions, he lacked diligence in 

noticing those depositions with less than 30 days in discovery, despite knowing the identities of 

his deponents for months. 

Plaintiff asserts that through December 2023, “one year into this litigation, the 

Government had produced a total of six (6) documents, all publicly available.” ECF No. 138 at 

2 (emphasis in original). This sentence is misleading. In December 2023 alone, the United States 

made three productions once the information became available. (ECF No. 137-5 (Jeffress Decl.) 

¶ 3). These productions total 388 documents consisting of 2,510 pages, and none of those 

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documents were public. Id. The United States contends that this is not a case that will require 

heavy reliance on any documentary evidence. But even if any records are important here, the 

records produced in December 2023 are the most important documents. They consist of the 

contracts between BAH and the IRS that Littlejohn worked on, Littlejohn’s training (including § 

6103 training) transcripts, and contract personnel records self-collected by the IRS Contracting 

Officer Representatives assigned to the contracts Littlejohn worked under. And although as a 

technical matter December 2023 is “one year into the litigation,” it is misleading to suggest that 

these records could have or should have been produced sooner when the Second Amended 

Complaint first identifying Littlejohn had been filed only on November 13, 2023. The Second 

Amended Complaint changed the entire course of litigation, and rendered Plaintiff’s first set of 

discovery requests largely irrelevant to the issue of whether Littlejohn is “an employee of the 

United States.” 

Since the Second Amended Complaint, the United States has timely complied with all 

discovery requests, often on an expedited basis. (See, e.g., ECF No. 84 allowing Plaintiff to seek 

DOJ files with a new request but requiring the United States to respond to the request in 14 days 

instead of 30 days allowed by the Federal Rules). This case involves just a single cause of action 

where the facts to make a prima facie case under the statute are known (i.e., BAH employee 

Littlejohn disclosed Plaintiff’s return or return information to ProPublica in violation of § 6103). 

Still, Plaintiff issued 93 requests to produce documents,109 requests for admissions, and 21 

interrogatories, all of which were compound resulting in interrogatives far exceeding the number 

permitted under the Federal Rules of Civil Procedure. The United States responded to all 

Plaintiff’s written discovery requests by January 30, 2024—two and a half months after the 

second amended complaint was filed. To put that in perspective, typically the United States gets 

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60 days just to answer a newly filed complaint. Fed. R. Civ. P. R. 12(a)(2). In this case, in just 

over 60 days, the United States responded to over 200 discovery requests. 

Plaintiff complains that the United States did not comply with the Court’s Post-Discovery 

Hearing Administrative Order (ECF No. 84) to review and produce electronically stored 

information (ESI) documents by January 30, 2024. (ECF No. 138 at 2). But the Post-Discovery 

Hearing Administrative Order did not set a production deadline. It required only the United 

States to respond or provide amended responses to outstanding discovery requests by the end of 

January. As Judge Goodman explained at the hearing: “I imagine this discovery is going to be 

produced on a rolling basis.” Dec. 29, 2023 Hr’g. Tr. 50:24-25 (Goodman, M. J.). And later, 

when Plaintiff raised this issue at another discovery hearing, Judge Goodman rejected Plaintiff’s 

claim that the United States violated the order. In its order following this later hearing, the Court 

noted the “magnitude of the effort being made by the Government’s attorneys” and required the 

United States to continue to produce ESI until March 19, 2024, the day which Littlejohn was 

schedule to be deposed. (ECF No. 99 at 2). By the date of the Littlejohn deposition, the United 

States produced 27,329 pages of documents—none of which Plaintiff’s counsel used with the 

witness. (ECF No. 137-05 at ¶ 11). To date, the United States has produced 45,972 pages of 

documents and its final production is due next week. 

Much of Plaintiff’s claim of government “stonewalling” stems from the parties’ dispute 

over the applicability of § 6103 to information TIGTA gathered in connection with its 

investigation of the ProPublica leak. At the court’s direction, the parties submitted briefs on that 

issue in January 2024, and Plaintiff again raised it in his motion to compel. On May 15, 

Magistrate Judge Goodman issued an order finding that the TIGTA material the United States 

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withheld constitutes the protected return information of Littlejohn. (ECF No. 141.) So, to the 

extent, Plaintiff argues we stonewalled discovery by properly asserting § 6103, he is mistaken. 

When discovery is viewed from the Second Amended Complaint (as it should be), the 

United States has exemplified cooperation, timeliness, and completeness. Thus, the Court should 

reject Plaintiff’s claim of “stonewalling” and deny his request for a 90-day extension of 

scheduling order. 

B. Plaintiff fails to show cause because he lacked diligence in pursuing his claim.

In the more than four-month period from when the United States provided written 

responses to all outstanding discovery on January 30, 2024, and to when the instant motion to 

modify seeking to extend discovery on May 8, 2024, Plaintiff’s discovery efforts were lethargic. 

Plaintiff’s efforts during those four months include the single deposition of Littlejohn on March 

19, 2024, and third-party subpoenas duces tecum on Littlejohn’s partner and her employer that 

have nothing to do with whether Littlejohn is “an employee of the United States.” Plaintiff 

glosses over his lack of discovery since receiving the United States’ responses in late January. 

But to demonstrate good cause, he must show that despite his best efforts he cannot complete 

discovery by the deadline. 

Plaintiff has not used his allotted time for discovery wisely, choosing to prioritize 

disputes over documents over taking depositions. (ECF No. 138 at 10.) But none of Plaintiff’s 

discovery disputes resulted in a stay of discovery. And he offers no reason why he could not 

pursue his disputes and take depositions. In litigation, one must often walk and chew gum at the 

same time to advance his case. That Plaintiff chose not to shows an absence of diligence and 

good cause. Indeed, his lack of diligence is demonstrated by the nearly two-week delay in filing 

this motion after conferring with undersigned counsel and the more than seven-week delay in 

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filing his motion to compel based on information discovered during Littlejohn’s deposition. And 

his motion to compel challenged for the first time the United States’ January 30, 2024, response 

to Plaintiff’s discovery request for the PIN file.2 These extended delays show lack of diligence. 

See Sosa, 133 F.3d at 1419 (denying for lack of diligence in pursuing claim when counsel took 

no oral deposition for nearly three months after deadline for amending a complaint passed); 

E.E.O.C. v. Excel Inc., 259 F.R.D. 652, 655 (N.D. Ga. 2008) (over two-month delay between the 

time a deposition was taken and the motion to amend was filed does show good cause). 

C. Plaintiff rejected the United States’ reasonable accommodation of a limited 

extension of discovery to allow time for depositions. 

Since receiving 8 notices of deposition on May 15, 2024, the United States has made 

reasonable efforts to accommodate Plaintiff’s request and assist in scheduling the depositions. 

Plaintiff has rebuffed these efforts. First, the United States advised Plaintiff that subpoenas were 

necessary for the 7 current and former IRS employees because they are not parties and that the 

depositions must take place where those individuals are located, not in Miami as originally 

noticed. The United States also offered to confirm witnesses’ availability and request permission 

to accept service of the subpoenas to ensure their attendance. Then, on May 17, 2024, Plaintiff 

issued, but did not serve, subpoenas irrespective of the witnesses’ availability, including setting 

depositions for non-business days. Realizing that the parties may need some additional time to 

schedule these depositions across the country to accommodate the schedules of witnesses and 

2 Plaintiff acknowledged that the PIN file was protected from disclosure under the Privacy Act. 

In fact, his motion to compel was seeking a court order under a statutory exception to allow the 

United States to produce such Privacy Act protected records. The Court ultimately granted this 

request, ordering any PIN records produced under a protective order. Before this order was 

entered, the United States was prohibited by law from disclosing this information. The United 

States was not stonewalling – it was complying with Federal law. Failure to seek it quicker than 

over four months after Plaintiff was notified the Privacy Act prevented disclosure is an 

unwarranted delay. 

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attorneys, the United States, during a phone call on May 20, 2024, proposed a limited extension 

of the discovery deadline from June 10, 2024, to June 28, 2024, to allow only for depositions. 

Plaintiff's counsel advised that they would need to take the request to Plaintiff. Rather than 

respond to the United States’ offer, Plaintiff began to personally serve the IRS deponents. The 

witnesses served as the filing of this response and counsel for the United States are prepared to 

move forward with the depositions on the subpoenaed dates. And so, an extension is no longer 

necessary as the parties both seem prepared to complete depositions before the close of discovery 

on June 10, 2024. We note, however, that if Plaintiff is unable to serve any witnesses within the 

time set in Local Rule 26.1(h), the witness need not appear. See Local Rule 26.1(h) (“Failure to 

comply with this Rule obviates the need for a protective order.”). 

CONCLUSION

For the above stated reasons, the Court should deny Plaintiff’s second motion to modify 

the Scheduling Order. The United States does not object to entry of an order consistent with the 

proposed order filed with this Response. 

(Signatures on next page)

 

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Dated: May 22, 2024 Respectfully Submitted 

DAVID A. HUBBERT 

Deputy Assistant Attorney General 

/s/ Stephanie Sasarak 

STEPHANIE A. SASARAK 

Maryland Bar No. 1012160096 

MARY ELIZABETH SMITH 

Maryland Bar No. 0712110235 

BEATRIZ T. SAIZ 

New Jersey Bar No. 024761995 

Trial Attorneys, Tax Division 

U.S. Department of Justice 

P.O. Box 14198 

Washington, D.C. 20044 

202-307-2089 (v) | 202-514-4963 (f) 

Stephanie.A.Sasarak@usdoj.gov 

Mary.E.Smith@usdoj.gov 

Beatriz.T.Saiz@usdoj.gov 

Counsel for the United States 

Of counsel: 

MARKENZY LAPOINTE 

United States Attorney 

Southern District of Florida 

 

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CERTIFICATE OF SERVICE 

I hereby certify that on May 22, 2024, I filed a copy of the foregoing document with the 

Clerk of Court using the CM/ECF system, which will send notification to counsel of record. 

 

/s/Stephanie Sasarak 

STEPHANIE SASARAK 

Trial Attorney 

 U.S. Dept. of Justice, Tax Division 

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