)
)
)
)
)
Plaintiffs,
)
)
v.
)
)
THE INTERNAL REVENUE SERVICE, et al., )
)
Defendants.
)
_______________________________________)
13939718.1
Respectfully submitted,
CAROLINE D. CIRAOLO
Acting Assistant Attorney General
Tax Division
/s/ Joseph A. Sergi
JOSEPH A. SERGI (DC 480837)
Senior Litigation Counsel
LAURA C. BECKERMAN (CA 278490)
LAURA M. CONNER (VA 40388)
Trial Attorneys
U.S. Department of Justice, Tax Division
555 4th Street, N.W.
Washington, D.C. 20001
(202) 514-2000
Joseph.A.Sergi@usdoj.gov
Of Counsel:
BENJAMIN C. GLASSMAN
Acting United States Attorney
MATTHEW J. HORWITZ (OH 0082381)
Assistant United States Attorney
221 East Fourth Street, Suite 400
Cincinnati, Ohio 45202
(513) 684-3711
Matthew.Horwitz@usdoj.gov
2
13939718.1
CERTIFICATE OF SERVICE
I hereby certify that on May 24, 2016, I caused the NOTICE OF COMPLIANCE WITH
COURTS ORDER APPROVING CLASS NOTICE PLAN to be served by filing the same with
the United States District Court for the Southern District of Ohio via the Courts CM/ECF
system.
/s/ Laura C. Beckerman
LAURA C. BECKERMAN
3
13939718.1
Exhibit
1
_____________
Tax Division
Please reply to:
Trial Attorney: Joseph A. Sergi
Attorneys Direct Line: 202-305-0868
Joseph.A.Sergi@usdoj.gov
CDC:MJK:JASergi
DJ 5-58-12409
CMN 2013101860
May 24, 2016
BY ELECTRONIC MAIL
AND FEDEX
Edward D. Greim
Dane C. Martin
Graves Garrett LLC
1100 Main Street, Suite 2700
Kansas City, MO 64105
edgreim@gravesgarrett.com
tgraves@gravesgarrett.com
Re:
Dear Counsel:
Pursuant to the Agreed Order Approving Proposed Class Notice and Class Notice Plan
(Docket No. 257), counsel for the United States mailed notice to the Potential Class Members.
This office provided the Mail Merge Comprehensive Address List to you (consisting of a list of
the Potential Class Members and all addresses to which notice was sent) as an attachment to an
email dated March 25, 2016. To date, this office has received opt-out requests from 40 entities,
and copies of the opt-out requests were provided to you by emails dated May 11, 2016 and May
13, 2016. In addition, we have received 165 notices marked return to sender. The notices for
most of these entities were sent to multiple addresses, so presumable the entity still received
notice of the action. However, for 35 of the entities, the notice was sent to the entitys only
address or all notices sent to the entitys addresses were returned, which presumably means that
those entities did not receive the direct-mail notice. We have provided a list of the envelopes
receives return to sender to you by email on April 8, 2013, April 22, 2013, and a final list was
provided today.
We have included the names of the 426 entities that have not opted out of the class action
as Attachment A. (Principal Class Members).
This office has compiled the IRS entity application files of the 426 members of the
Principal Class Members, which have been provided on the enclosed flash drive. The password
has been provided via email.
-2Please let us know if you have any questions regarding this production.
Sincerely yours,
s/ Joseph A. Sergi
Enclosures as stated
Entity Name
10TH AMENDMENT FOUNDATION, INC.
1776 NATION, INC.
1776 TEA PARTY
4 CORNERS LIBERTY RESTORATION GROUP
912 LANE COUNTY
912 PROJECT FORT WORTH, INC.
912 PROJECT OF BURLINGTON COUNTY
A CONSERVATIVE WORD
AAOL AMERICANS AGAINST OPPRESSIVE
ABU EDUCATION FUND
ACROSS THE AISLE FOUNDATION
ACTION COMMITTEE FOR TOMORROW
ACTIVE LIBERTY ALLIANCE INC
ACTRIGHT ACTION
ACTRIGHT EDUCATIONAL TRUST FUND
ADP ACTION, INC.
ALABAMA FAIRTAX EDUCATIONAL ASSOCIATION INC.
ALEC NOW
ALEXANDER HAMILTON INSTITUTE FOR
ALLEN AREA PATRIOTS
ALLEN WEST FOUNDATION
ALLIANCE FOR A BETTER GEORGIA INC
ALLIANCE FOR A BETTER UTAH INC
ALLIANCE FOR SELF-GOVERANCE
AMERICA IS NOT STUPID INC
AMERICAN ACADEMY FOR CONSTITUTIONAL EDUCATION,
INC.
AMERICAN EGYPTIAN STRATEGIC ALLIANCE
AMERICAN FREEDOM AND ENTERPRISE FOUNDATION, INC.
AMERICAN GREATNESS INC
AMERICAN JUNTO INC
AMERICAN LEADERSHIP COUNCIL
AMERICAN OPPORTUNITY PROJECT
AMERICAN PATRIOT
AMERICAN PATRIOTS FOR CONSERVATIVE ACTION, INC.
AMERICAN SOLUTIONS FOR WINNING THE FUTURE
AMERICAN TEA PARTY CONGRESS A NJ NONPROFIT CORP
AMERICAN VOICE FOR FREEDOM INC
AMERICANS FOR RESPONSIBLE LEADERSHIP
AMERICA'S TRUST, INC.
ARIZONA CITIZENS UNITED
ARIZONA PATRIOTS ALLIANCE INC
ARIZONA STATE FAIRTAX
ARKANSANS FOR COMMON SENSE
ARKANSAS CAMPAIGN FOR LIBERTY
ASHEVILLE TEA PARTY, INC.
1of10
May24,2016
May24,2016
3of10
May24,2016
172
173
174
175
176
177
178
4of10
May24,2016
May24,2016
6of10
May24,2016
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
May24,2016
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
8of10
May24,2016
May24,2016
VOCES
VOLUSIA 912 PATRIOTS, INC.
WAYNE COUNTY TEA PARTY, INC.
WE THE PEOPLE 501
WE THE PEOPLE ALLIANCE INC
WE THE PEOPLE EUGENE
WE THE PEOPLE IOWA
WE THE PEOPLE OF CONNECTICUT INC
WE THE PEOPLE OF MARYLAND, INC.
WE THE PEOPLE OF NEW YORK INC
WE THE PEOPLE OF TEXAS INC TEXAS PATRIOTS TEA PARTY
412
413
414
415
416
417
418
419
420
421
422
423
424
10of10
May24,2016