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.

DECLARATION OF JASON STERNBERG IN SUPPORT OF 

PLAINTIFF’S EXPEDITED MOTION TO COMPEL DISCOVERY

I, JASON STERNBERG, hereby declare the following: 

1. I am a partner with the law firm Quinn Emanuel Urquhart & Sullivan, LLP, and 

counsel for Plaintiff Kenneth C. Griffin (“Mr. Griffin”) in the above-captioned action. 

2. I respectfully submit this Declaration in Support of Plaintiff’s Expedited Motion to 

Compel Discovery. 

3. Attached hereto as Exhibit 1 is a true and correct copy of correspondence from 

Defendants’ counsel to Plaintiff’s counsel on May 29, 2024.

4. Attached hereto as Exhibit 2 is a true and correct copy of the Declaration of 

Jonathan E. Jacobson, Trial Attorney, U.S. Department of Justice, Criminal Division, Public 

Integrity Section, signed on May 29, 2024. 

5. Attached hereto as Exhibit 3 is a true and correct copy of the Declaration of Scott 

H. Moffit, Special Agent in Charge, Treasury Inspector General for Tax Administration, signed

on May 29, 2024. 

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6. Attached hereto as Exhibit 4 is a true and correct copy of a document produced by 

Defendants on May 29, 2024, which has been Bates stamped as IRS-0000849. This document was 

designated as confidential under the Protective Order and, as such, will be filed under seal in its 

entirety. 

7. Attached hereto as Exhibit 5 is a true and correct copy of a document produced by 

Defendants on May 29, 2024, which has been Bates stamped as IRS-0000847. This document was 

designated as confidential under the Protective Order and, as such, will be filed under seal in its 

entirety. 

8. Attached hereto as Exhibit 6 is a true and correct copy of a document produced by 

Defendants on May 29, 2024, which has been Bates stamped as IRS-0000895. This document was 

designated as confidential under the Protective Order and, as such, will be filed under seal in its 

entirety. 

9. Attached hereto as Exhibit 7 is a true and correct copy of a document produced by 

Defendants on May 29, 2024, which has been Bates stamped as IRS-0000702. This document was 

designated as confidential under the Protective Order and, as such, will be filed under seal in its 

entirety. 

10. Attached hereto as Exhibit 8 is a true and correct copy of a document produced by 

Defendants on May 29, 2024, which has been Bates stamped as IRS-0000705. This document was 

designated as confidential under the Protective Order and, as such, will be filed under seal in its 

entirety. 

11. Attached hereto as Exhibit 9 is a true and correct copy of a document produced by 

Defendants on May 29, 2024, which has been Bates stamped as IRS-0000216. This document was 

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designated as confidential under the Protective Order and, as such, will be filed under seal in its 

entirety. 

12. Attached hereto as Exhibit 10 is a true and correct copy of a document produced 

by Defendants on May 29, 2024, which has been Bates stamped as DOJ-000000001. This 

document was designated as confidential under the Protective Order and, as such, will be filed 

under seal in its entirety. 

13. Attached hereto as Exhibit 11 is a true and correct copy of the United States’ 

Opposition to Counterclaim Plaintiff’s Motion for Leave to Amend (ECF 265) in United States v. 

Musin, et al., No. 4:09-cv-00062 (S.D. Iowa March 10, 2011). 

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

Executed on June 3, 2024.

/s/ Jason D. Sternberg

Jason D. Sternberg 

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