PRIMARY
SOURCES

A. The Settlement Agreement in Trump v. Internal Revenue Service, No. 1:26-cv-20609 (S.D. Fla.), has created the Anti-Weaponization Fund (the "Fund"). The Settlement Agreement directed the Attorney General to issue an order establishing funding and any other relevant requirements for the Fund. B. Capitalized terms in this document shall have the same meaning as in the Settlement Agreement. C. The United States RELEASES, WAIVES, ACQUITS, and FOREVER DISCHARGES each of the Plaintiffs from, and is hereby FOREVER BARRED and PRECLUDED from prosecuting or pursuing, any and all claims, counterclaims, causes of action, appeals, or requests for any relief, including injunctive relief, monetary relief, damages, examinations or similar or related reviews, appeals, debt relief, costs, attorney's fees, expenses, and/or interest, whether presently known or unknown, that—as of the Effective Date of the Settlement Agreement—have been or could have been asserted by Defendants against any of the Plaintiffs or related or affiliated individuals (including, without limitation, family or others filing jointly), or parties including trusts, parent, sister, or related companies, affiliates, and subsidiaries, by reason of, with respect to, in connection with, or which arise out of (1) any matters that were raised or could have been raised in the Case or the Pending Agency Claims; (2) Lawfare and/or Weaponization; or (3) any matters currently pending or that could be pending (including tax returns filed before the Effective Date) before Defendants or other agencies or departments. Signed: Todd Blanche Acting Attorney General

SETTLEMENT AGREEMENT, TRUMP V. IRS (SDFL) I. INTRODUCTION This is a civil lawsuit ("the Case") brought by President Donald J. Trump, Donald J. Trump, Jr., Eric Trump, and The Trump Organization, LLC ("Plaintiffs") against the Internal Revenue Service ("IRS") and the U.S. Department of the Treasury ("Defendants") under 26 U.S.C. § 6103, 26 U.S.C. § 7431, and 5 U.S.C. § 552(a)(e)(10). In the interest of resolving the dispute between the parties, they hereby stipulate and agree as follows: II. RECITALS A. On January 29, 2026, Plaintiffs filed a complaint in the U.S. District Court for the Southern District of Florida, stating that a former IRS employee/contractor, Charles Littlejohn had illegally obtained access to, and illegally disclosed, Plaintiffs' tax returns and/or tax return information to media outlets in violation of the Internal Revenue Code and the Privacy Act. Counsel for Plaintiffs have indicated that, but for this settlement, they would intend to amend their complaint, including in order to likely add a putative class claim. B. President Trump has also submitted two claims for relief pursuant to the Federal Tort Claims Act, based on the unlawful raid on Mar-a-Lago, in Palm Beach, Florida, in August of 2022, and the Russia-collusion hoax throughout his first term as President, and beyond (together, "the Pending Agency Claims"). Those claims are currently pending at the administrative level. C. The conduct alleged in the Case and in the Pending Agency Claims is representative of the sustained use of the levers of government power by Democrat elected officials, political and career federal employees, contractors, and agents in order to target individuals, groups, and entities for improper and unlawful political, personal, and/or ideological reasons ("Lawfare" and "Weaponization"). Other well-known examples of Lawfare and Weaponization include the Biden Administration's abuse of the FACE Act, the Biden Administration's wrongful labeling of certain parents as domestic terrorists, and the IRS's targeting of groups based on improper ideological criteria. D. To bring the Case and the Pending Agency Claims to a close FOREVER and FINALLY, the parties have determined to settle the Case and Pending Agency Claims, effective May 18, 2026 ("Effective Date"). III. RELIEF AND LEGAL AUTHORITY A. Plaintiffs will receive a formal apology but no monetary payment or damages of any kind. The government also RELEASES, WAIVES, and FOREVER DISCHARGES each Plaintiff from any and all claims that could have been asserted by Defendants by reason of any matters raised or could have been raised in the Case or Pending Agency Claims, Lawfare and/or Weaponization, or any matters currently pending before Defendants or other agencies. B. To provide a systematic process to hear and redress claims of others who, like Plaintiffs, state that they incurred harm from similar Lawfare and Weaponization, the parties agree to the creation of The Anti-Weaponization Fund ("Fund"), to be established and funded in an accompanying order of the Attorney General. The corpus of The Anti-Weaponization Fund's funding is based on the projected valuation of future claimants' claims and is not taxable income as to Plaintiffs. C. The corpus of the Fund shall be $1,776,000,000. D. The legal authority for the establishment of the Fund includes the Automatic Payment of Judgments Act, 31 U.S.C. § 1304 (the Judgment Fund), and 28 U.S.C. § 2414. IV. COMPOSITION AND OPERATION OF THE ANTI-WEAPONIZATION FUND A. An accompanying order of the Attorney General, issued within 30 days of the Effective Date, shall establish funding and any other relevant requirements, rules, conditions, terms, and waivers, which shall be treated as incorporated herein. B. The Anti-Weaponization Fund shall consist of five Members. Within 30 days of the Effective Date, the Attorney General shall issue an order appointing the Members, including the Chair of The Anti-Weaponization Fund. One of the Members shall be chosen in consultation with congressional leadership. The Members shall serve until The Anti-Weaponization Fund is concluded, unless they resign or are removed by the President, who can remove any Member without cause. A quorum is three Members. A majority of a quorum is authorized to take action. C. The Anti-Weaponization Fund shall have the power to determine its own procedures for submitting, receiving, processing, and granting or denying claims. The Anti-Weaponization Fund may make those procedures public in whole or in part, in its discretion. D. The Anti-Weaponization Fund shall have the power to issue formal apologies, issue monetary relief owed to claimants as a result of their legal rights, grant claims in whole or in part, deny claims in whole or in part, defer review of claims, and receive and request evidence or other support for claims, including requesting information from, or consulting with, federal agencies. E. On a quarterly basis, or otherwise as directed by the Attorney General, The Anti-Weaponization Fund shall provide to the Attorney General a confidential written report that includes the name and address of each claimant who has received any relief and if so, nature of such relief. F. The Department of Justice, or third-party contractor of the agency as designated by the Attorney General, may audit the claims submitted pursuant to this Agreement. G. The Anti-Weaponization Fund shall cease processing claims no later than December 1, 2028. After December 15, 2028, The Anti-Weaponization Fund shall transfer the balance of The Anti-Weaponization Fund account to the Department of Commerce, Interior, or another appropriate federal government account as designated by the President. H. The Anti-Weaponization Fund shall take reasonable steps to protect private personal and financial information submitted to it under this Settlement Agreement. V. ELIGIBILITY AND CLAIMS PROCESS A. To be eligible for relief, a claimant must assert at least one legal claim stating that the claimant was a victim of Lawfare and/or Weaponization. B. In evaluating claims, The Anti-Weaponization Fund shall consider the totality of the circumstances, including: (a) the strength of the claim and supporting evidence; (b) the claimant's actions; (c) the claimant's actual damages; (d) reasonable attorneys' fees paid by the claimant as a result of the Lawfare and Weaponization; (e) any time the claimant spent in prison or otherwise in federal custody as a result of the Lawfare and Weaponization; (f) whether and to what extent the claimant has already obtained any form of relief from any source; and (g) other factors The Anti-Weaponization Fund deems just and appropriate. C. Monetary payments from The Anti-Weaponization Fund shall be final and not subject to judicial review. D. Submission of a claim shall be voluntary. E. The Anti-Weaponization Fund may make the claims process public in whole or in part. F. No information identifying claimants or the amount of any payment shall be made public by the Anti-Weaponization Fund without the written consent of the claimant. VI. ENFORCEMENT A. This Settlement Agreement is enforceable and challengeable solely by Plaintiffs, Defendants, and the United States. B. Because the claims process is voluntary, there shall be no appeal, arbitration, or judicial review of claims, offers, or other determinations made by The Anti-Weaponization Fund. Denial by The Anti-Weaponization Fund, the pendency of a claim, or rejection of an offer by a claimant does not preclude a claimant from seeking judicial or other relief outside The Anti-Weaponization Fund process, if otherwise allowed by law. VII. INTEGRATION AND COUNTERPARTS This Settlement Agreement, including the accompanying orders by the Attorney General, constitutes the entire agreement of the Parties, and no prior statement, representation, agreement, or understanding, oral or written, that is not contained herein, will have any force or effect. This Settlement Agreement may be executed in counterparts. All executed counterparts and each of them shall be deemed to be one and the same instrument. VIII. MODIFICATION This Settlement Agreement may be modified only with the written agreement of the Parties. IX. DUTIES CONSISTENT WITH LAW AND REGULATIONS Nothing contained in this Settlement Agreement shall impose on Defendants or their agents, employees, or contractors any duty, obligation, or requirement, the performance of which would be inconsistent with federal statutes. The Parties to this Settlement Agreement shall defend against any challenges to it in any forum. X. SEVERABILITY Should any provision of this Settlement Agreement be found by a court to be invalid or unenforceable, then the validity of other provisions of this Settlement Agreement shall not be affected or impaired, and such provisions shall be enforced to the maximum extent possible, including by modification by mutual agreement, if appropriate. XI. DISMISSAL OF THE CASE AND WITHDRAWAL OF PENDING AGENCY CLAIMS Plaintiffs agree to file a dismissal with prejudice of the Case under Rule 41(a)(1)(A)(i) on or before May 18, 2026. The parties further agree that by June 15, 2026, they will withdraw, terminate, and no longer pursue in any setting or forum the Pending Agency Claims. AGREED: For Plaintiffs: Daniel Z. Epstein / Alejandro Brito — Dated: May 18, 2026 For the United States: Stanley E. Woodward, Jr., Associate Attorney General — Dated: May 18, 2026 For the Internal Revenue Service: Frank J. Bisignano, Chief Executive Officer — Dated: May 18, 2026

PRESS RELEASE Justice Department Announces Anti-Weaponization Fund Monday, May 18, 2026 — For Immediate Release — Office of Public Affairs Part of settlement agreement in President Donald J. Trump v. Internal Revenue Service The U.S. Department of Justice today announced that as a part of the settlement agreement in President Donald J. Trump v. Internal Revenue Service, the Attorney General established "The Anti-Weaponization Fund" to provide a systematic process to hear and redress claims of others who suffered weaponization and lawfare. The plaintiffs in the case, President Donald J. Trump, Donald J. Trump, Jr., Eric Trump, and the Trump Organization, LLC, filed suit against the Treasury and IRS in Southern District of Florida federal court following the leak of their tax returns. Per the settlement, plaintiffs will receive a formal apology but no monetary payment or damages of any kind. They have agreed, in exchange for the creation of this fund, to drop their pending lawsuit with prejudice, and also withdraw two administrative claims including for damages resulting from the unlawful raid of Mar-a-Lago and the Russia-collusion hoax. "The machinery of government should never be weaponized against any American, and it is this Department's intention to make right the wrongs that were previously done while ensuring this never happens again," said Acting Attorney General Todd Blanche. "As part of this settlement, we are setting up a lawful process for victims of lawfare and weaponization to be heard and seek redress." "The use of government power to target individuals or entities for improper and unlawful political, personal, or ideological reasons should not be tolerated by any Administration," said Principal Associate Deputy Attorney General Trent McCotter. The Fund will have the power to issue formal apologies and monetary relief owed to claimants. Submission of a claim is voluntary. There are no partisan requirements to file a claim. Any money left when the Fund ceases operations will revert to the Federal Government. The Fund will receive $1.776 billion and will come from the Judgment Fund, which is a perpetual appropriation allowing DOJ to settle and pay cases. On a quarterly basis, the Fund shall send a report to the Attorney General outlining who has received relief and what form of relief was awarded. At the Attorney General's direction, the Fund can be audited. The Fund must take steps to protect private information and avoid fraud. The Fund shall cease processing claims no later than December 1, 2028. There is legal precedent for such a Fund, most notably the "Keepseagle" case where the Obama Administration created a $760 million fund to redress various claims alleging racism against the federal government over a period of decades. In Keepseagle, hundreds of millions of dollars remaining in the fund were distributed to non-profits and NGOs that never made claims, whereas any money remaining in the Anti-Weaponization Fund will revert to the federal government. The Obama DOJ settled by putting $680 million from the judgment fund into a bank account for a single claims administrator to dole out. In Keepseagle the remaining money — which ended up being over $300 million — was distributed to the entities that had not even submitted claims. The Fund will consist of five members appointed by the Attorney General. One Member will be chosen in consultation with congressional leadership. The President can remove any member, but a replacement must be chosen the same way as the replaced member was selected. Updated May 19, 2026

EXECUTIVE ORDER 14215 ENSURING ACCOUNTABILITY FOR ALL AGENCIES By the authority vested in me as President by the Constitution and the laws of the United States of America, it is hereby ordered: Section 1. Policy and Purpose. The Constitution vests all executive power in the President and charges him with faithfully executing the laws. Since it would be impossible for the President to single-handedly perform all the executive business of the Federal Government, the Constitution also provides for subordinate officers to assist the President in his executive duties. In the exercise of their often-considerable authority, these executive branch officials remain subject to the President's ongoing supervision and control. The President in turn is regularly elected by and accountable to the American people. However, previous administrations have allowed so-called "independent regulatory agencies" to operate with minimal Presidential supervision. These regulatory agencies currently exercise substantial executive authority without sufficient accountability to the President, and through him, to the American people. Moreover, these regulatory agencies have been permitted to promulgate significant regulations without review by the President. These practices undermine such regulatory agencies' accountability to the American people and prevent a unified and coherent execution of Federal law. For the Federal Government to be truly accountable to the American people, officials who wield vast executive power must be supervised and controlled by the people's elected President. Therefore, in order to improve the administration of the executive branch and to increase regulatory officials' accountability to the American people, it shall be the policy of the executive branch to ensure Presidential supervision and control of the entire executive branch. Moreover, all executive departments and agencies, including so-called independent agencies, shall submit for review all proposed and final significant regulatory actions to the Office of Information and Regulatory Affairs (OIRA) within the Executive Office of the President before publication in the Federal Register. Sec. 2. Definitions. (a) The term "employees" shall have the meaning given that term in section 2105 of title 5, United States Code. (b) The term "independent regulatory agency" shall have the meaning given that term in section 3502(5) of title 44, United States Code. This order shall not apply to the Board of Governors of the Federal Reserve System or to the Federal Open Market Committee in its conduct of monetary policy. This order shall apply to the Board of Governors of the Federal Reserve System only in connection with its conduct and authorities directly related to its supervision and regulation of financial institutions. (c) The term "independent regulatory agency chairman" shall mean, with regard to a multi-member independent regulatory agency, the chairman of such agency, and shall mean, with regard to a single-headed independent regulatory agency, such agency's chairman, director, or other presiding officer. (d) The term "head" of an independent regulatory agency shall mean those appointed to supervise independent regulatory agencies and in whom the agencies' authorities are generally vested. Sec. 3. OIRA Review of Agency Regulations. (a) Section 3(b) of Executive Order 12866 of September 30, 1993, as amended, is hereby amended to expand "Agency" to include all authorities of the United States that are "agencies" under 44 U.S.C. 3502(1), including the Federal Election Commission, subject to the exceptions for the Federal Reserve in monetary policy matters. (b) The Director of the Office of Management and Budget (OMB) shall provide guidance on implementation of this order. Agency submissions by independent regulatory agencies shall commence within the earlier of 60 days from the date of this order, or completion of such implementation guidance. Sec. 4. Performance Standards and Management Objectives. The Director of OMB shall establish performance standards and management objectives for independent agency heads, as appropriate and consistent with applicable law, and report periodically to the President on their performance and efficiency in attaining such standards and objectives. Sec. 5. Apportionments for Independent Regulatory Agencies. The Director of OMB shall, on an ongoing basis: (a) review independent regulatory agencies' obligations for consistency with the President's policies and priorities; and (b) consult with independent regulatory agency chairmen and adjust such agencies' apportionments by activity, function, project, or object, as necessary and appropriate, to advance the President's policies and priorities. Sec. 6. Additional Consultation with the Executive Office of the President. (a) Subject to subsection (b), independent regulatory agency chairmen shall regularly consult with and coordinate policies and priorities with the directors of OMB, the White House Domestic Policy Council, and the White House National Economic Council. (b) The heads of independent regulatory agencies shall establish a position of White House Liaison in their respective agencies. Such position shall be in grade 15 of the General Schedule and shall be placed in Schedule C of the excepted service. (c) Independent regulatory agency chairmen shall submit agency strategic plans to the Director of OMB for clearance prior to finalization. Sec. 7. Rules of Conduct Guiding Federal Employees' Interpretation of the Law. The President and the Attorney General, subject to the President's supervision and control, shall provide authoritative interpretations of law for the executive branch. The President and the Attorney General's opinions on questions of law are controlling on all employees in the conduct of their official duties. No employee of the executive branch acting in their official capacity may advance an interpretation of the law as the position of the United States that contravenes the President or the Attorney General's opinion on a matter of law, including but not limited to the issuance of regulations, guidance, and positions advanced in litigation, unless authorized to do so by the President or in writing by the Attorney General. Sec. 8. General Provisions. (a) If any provision of this order, or the application of any provision to any person or circumstance, is held to be invalid, the remainder of this order and the application of its provisions to any other persons or circumstances shall not be affected thereby. (b) Nothing in this order shall be construed to impair or otherwise affect: (i) the authority granted by law to an executive department, agency, or the head thereof; or (ii) the functions of the Director of the Office of Management and Budget relating to budgetary, administrative, or legislative proposals. (c) This order shall be implemented consistent with applicable law and subject to the availability of appropriations. (d) This order is not intended to, and does not, create any right or benefit, substantive or procedural, enforceable at law or in equity by any party against the United States, its departments, agencies, or entities, its officers, employees, or agents, or any other person. THE WHITE HOUSE February 18, 2025 — Published in the Federal Register, Vol. 90, No. 36, February 24, 2025, Pages 10447–10452 (Doc. 2025-03063)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRIA DIVISION Andrew Floyd, et al., Plaintiffs, v. Department of Justice, et al., Defendants. Case No. 1:26-cv-01399-LMB DEFENDANTS' NOTICE OF FILING The Court stated that it will dismiss this case as moot only if "Acting Attorney General Todd Blanche, Associate Attorney General Stanley Woodward, Jr., and Secretary of the Treasury Scott Bessent FILE a declaration under penalty of perjury that they will not take any action to create or operate the Anti-Weaponization Fund, and that the Anti-Weaponization Fund will not proceed in any manner, or under any name." ECF No. 85. "If such a declaration is not filed by June 19, 2026, the Court will issue a Scheduling Order and require defendants to file a responsive pleading by July 17, 2026." Id. Such declarations are unnecessary and the compelled testimony of senior officials from the Executive Branch implicates serious separation of powers concerns. The Acting Attorney General has testified before Congress that the Fund is "not going forward, period." House Appropriations Committee, Oversight Hearing – Department of Justice, at 40:30-42:50. [Available at https://www.youtube.com/watch?v=rt_bIvnvq3o.] Undersigned counsel have twice signed briefs reaffirming that "the Fund is not going forward." And counsel for Defendants has twice said substantially the same thing in open court. All these statements were made against the backdrop of serious penalties for falsity. See 18 U.S.C. § 1001; Fed. R. Civ. P. 11(b)–(c). So there is no reason why declarations should affect the Court's mootness analysis. As a federal court held in a related case: “Federal courts lack jurisdiction over claims that are moot. And mootness must be assessed at all stages of the litigation to ensure that a live controversy remains. On the present record [the court is] not persuaded that such a live controversy exists. The government has represented, both in its filings and through statements by the Acting Attorney General before Congress, that the challenged fund is, quote, is not moving forward, close quote, and, indeed, quote, will not, close quote, move forward. [The court is] entitled to credit the government's affirmative representations, particularly when they have been orally repeated in court hearings, stated in formal court filings, and announced by senior officials. I'm expressly relying on these representations to deny the TRO today.” Citizens for Responsibility and Ethics in Washington v. U.S. DOJ, et al., No. 26-cv-1789, Tr. of TRO Mot. Hr'g 19:21–20:9 (June 10, 2026) (filed at ECF No. 83). Nor is there any basis for the court to compel testimony from the Associate Attorney General and two Cabinet members. The point of Article III limitations on judicial review is to prevent such overreach. Indeed, "[t]he duties of high-ranking executive officers should not be interrupted by judicial demands for information that could be obtained elsewhere," including here through other competent evidence and representations. In re Cheney, 544 F.3d 311, 314 (D.C. Cir. 2008) (per curiam); see also In re Musk, 169 F.4th 445, 448 (4th Cir. 2026) (granting petition for mandamus relief because, to depose "high-ranking government officials," when other options existed "implicate[d] separation of powers concerns"); In re Paxton, 60 F.4th 252, 258–259 (5th Cir. 2023) (concluding that the district court "clearly abused its discretion" when it required "apex" testimony from high-ranking officials who "cannot perform their duties if they are not personally shielded from the burdens of litigation"); In re U.S. Dep't of Educ., 25 F.4th 692, 703 (9th Cir. 2022) ("If the information is not absolutely needed for a case, [courts] cannot allow a deposition to disrupt the normal governmental balance of powers."); In re United States (Jackson), 624 F.3d 1368, 1372 (11th Cir. 2010) ("[T]he compelled appearance of a high-ranking officer of the executive branch in a judicial proceeding implicates the separation of powers."). Accordingly, the Court's demands are unnecessary. And its presumption that mootness can arise only by compelling testimony from three senior government officials "implicate[s] separation of powers concerns". In re Musk, 169 F.4th 445. As stated multiple times, the Fund is not moving forward. The transcript of the Acting Attorney General's unequivocal testimony to Congress is attached. Exhibit A. The Court should dismiss this case as moot and for lack of standing and ripeness. Dated: June 19, 2026 STANLEY E. WOODWARD, JR. Associate Attorney General /s/ ANDREW J. BLOCK Andrew J. Block (VSB No. 91537) Senior Counsel to the Associate Attorney General U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530 Counsel for Defendants CERTIFICATE OF SERVICE I hereby certify that on June 19, 2026, I filed the foregoing document with the Clerk of Court using the Court's CM/ECF system, thereby serving all counsel who have appeared in this case. /s/ Andrew J. Block Andrew Block

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA ALEXANDRIA DIVISION Andrew Floyd, et al., Plaintiffs, v. Department of Justice, et al., Defendants. Case No. 1:26-cv-01399-LMB DEFENDANTS' RESPONSE TO PLAINTIFFS' MOTION FOR A TEMPORARY RESTRAINING ORDER OR, IN THE ALTERNATIVE, A PRELIMINARY INJUNCTION AND FOR A 5 U.S.C. § 705 STAY INTRODUCTION This dispute concerns an Anti-Weaponization Fund that had not been set up and is now not going forward. As a result, Plaintiffs' claims are not justiciable. Federal courts may resolve "active political debates . . . only if necessary to do so in the course of deciding an actual 'case' or 'controversy'" as those words are "used in the Constitution." Hollingsworth v. Perry, 570 U.S. 693, 697, 700 (2013). Article III of the Constitution thus "ensures that [courts] act as judges, and do not engage in policymaking properly left to elected representatives." Id. at 700. The United States thus opposes Plaintiffs' request for relief on justiciability and other grounds—not because the Fund will continue (it will not), but to protect the government's institutional interests in the proper application of Article III limitations on judicial review. BACKGROUND On January 29, 2026, President Trump, Donald J. Trump, Jr., Eric Trump, and The Trump Organization, LLC filed a complaint in the U.S. District Court for the Southern District of Florida. They asserted claims under 26 U.S.C. § 6103, 26 U.S.C. § 7431, and 5 U.S.C. 552(a)(e)(10). Their counsel indicated that they intended to amend their complaint to add a putative class claim. President Trump had also submitted Federal Tort Claims Act (FTCA) administrative claims for relief alleging an unlawful raid on his Mar-a-Lago home in Palm Beach, Florida, as well as unlawful targeting in relation to the infamous Russia-collusion hoax. Because President Trump is the Chief Executive, his lawsuits against the United States presented unique challenges. At the same time, Presidents do not forfeit their legal rights. Ultimately, the federal defendants agreed to resolve the litigation and pre-litigation FTCA administrative claims without the United States having to give the plaintiffs "monetary payment or damages of any kind," as memorialized by a Settlement Agreement dated May 18, 2026. Instead, the plaintiffs would "receive a formal apology." The plaintiffs waived all claims that could have been asserted in connection with the litigation and administrative claims process. And the United States agreed to establish "a systematic process to hear and redress claims of others who, like Plaintiffs, state that they incurred harm from similar Lawfare and Weaponization" through "The Anti-Weaponization Fund." The Settlement Agreement states that the Attorney General, within 30 days of the settlement, would enter an order to "establish funding and any other relevant requirements, rules, conditions, terms, and waivers" and "issue an order appointing [five] Members, including the Chair." "One of the Members shall be chosen in consultation with congressional leadership," and all members would continue in their roles until the Fund concludes, "unless they resign or are removed by the President." On May 18, 2026, the Attorney General issued an order pursuant to the Settlement Agreement. The order stated that the United States would "provide the U.S. Department of the Treasury with all necessary forms and documentation to direct a payment of $1,776,000,000 to an account for the sole use by the Anti-Weaponization Fund" "[w]ithin 60 days." The order also clarified that Fund Members would serve on a volunteer basis. PROCEDURAL HISTORY On May 22, 2026, Plaintiffs — Andrew Floyd, a former career federal prosecutor who was fired; the City of New Haven, Connecticut; the National Abortion Federation (NAF); and Common Cause — filed this lawsuit. On the premise that the "Fund is available only to claimants who assert that they were targeted by 'Democrat' administrations," they claim the Fund violates the First Amendment and the Equal Protection Clause. They also claim the Fund violates the separation of powers and the APA. Although counsel for the United States informed counsel for Plaintiffs that no money had been transferred to the Fund and no Members had been appointed, Plaintiffs moved for a temporary restraining order or preliminary injunction and for a stay under 5 U.S.C. § 705. "[T]o ensure that no funds are irreversibly disbursed . . . while plaintiffs' motion is pending," the Court temporarily enjoined Defendants "from taking any further action pursuant to the creation or operation of the Anti-Weaponization Fund, which includes the transferring of money to the Fund; the consideration of any claims submitted to the Fund; and the disbursing of any funds from the Fund." Political debate surrounding the Fund continued. On June 2, 2026, the Acting Attorney General testified at a congressional hearing: Q: "Are we moving forward with the Fund?" A: ". . . We're not moving forward with the Fund . . . We are not moving forward with the Fund, period. . . . The reasons for the Fund remain as important as they were before, but we are not moving forward with the Fund." Q: "Not moving forward ever?" A: "Correct." Q: "Oh, there's no more Fund then." A: "Well, to the extent there was a Fund. Remember, the Fund wasn't set up yet. There were no commissioners named, there were no claims made yet, so yes we are not moving forward with the Fund." Q: "Is there any way that you could put this in writing . . . ?" A: "I'm telling you it's not . . . Notwithstanding what we do in those litigations and protecting our rights and making sure those rights are protected, we're not moving forward with the Fund." House Appropriations Committee, Oversight Hearing – Department of Justice, at 40:30-42:50. ARGUMENT I. PLAINTIFFS' CLAIMS ARE NOT JUSTICIABLE A. This Case Is Moot. This case is moot because "the issues presented are no longer live [and] the parties lack a legally cognizable interest in the outcome." Already, LLC v. Nike, Inc., 568 U.S. 85, 91 (2013). The Acting Attorney General's statements to Congress make it "absolutely clear the allegedly wrongful behavior could not reasonably be expected to recur." Id. B. Plaintiffs Lack Standing. Federal courts do not "operate as an open forum for citizens 'to press general complaints about the way in which government goes about its business.'" All. for Hippocratic Med., 602 U.S. at 379. "[T]o establish standing, a plaintiff must show (i) that he suffered an injury in fact that is concrete, particularized, and actual or imminent; (ii) that the injury was likely caused by the defendant; and (iii) that the injury would likely be redressed by judicial relief." TransUnion, 594 U.S. at 423. C. Plaintiffs' Claims Are Not Ripe For Adjudication. "Ripeness doctrine reflects the prudential concern that courts should not be forced to engage in adjudication divorced from any specific factual context." Retail Industry Leaders Ass'n v. Fielder, 475 F.3d 180, 188 (4th Cir. 2007). II. PLAINTIFFS HAVE NO LIKELIHOOD OF SUCCESS ON THE MERITS [Detailed analysis of First Amendment, Equal Protection, Separation of Powers, and APA claims — all fail for threshold justiciability reasons and on the merits.] CONCLUSION The Court should deny Plaintiffs' motion for a temporary restraining order or a preliminary injunction and a § 705 stay. Dated: June 5, 2026 STANLEY E. WOODWARD, JR. Associate Attorney General /s/ ANDREW J. BLOCK Andrew J. Block (VSB No. 91537) Senior Counsel to the Associate Attorney General U.S. Department of Justice

DEFENDANTS' RESPONSE TO PLAINTIFF'S MOTION FOR A TEMPORARY RESTRAINING ORDER IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Citizens for Responsibility and Ethics in Washington, Plaintiff, v. U.S. Department of Justice, et al., Defendants. INTRODUCTION This dispute concerns an Anti-Weaponization Fund that had not been set up and is now not going forward. As a result, Plaintiff's claims are not justiciable. The United States thus opposes Plaintiff's request for relief on justiciability and other grounds — not because the Fund will continue (it will not), but to protect the government's institutional interests in the proper application of Article III limitations on judicial review. BACKGROUND On January 29, 2026, President Trump, Donald J. Trump, Jr., Eric Trump, and The Trump Organization, LLC filed a complaint in the U.S. District Court for the Southern District of Florida. They asserted claims under 26 U.S.C. § 6103, 26 U.S.C. § 7431, and 5 U.S.C. 552(a)(e)(10). Their counsel indicated that they intended to amend their complaint to add a putative class claim. President Trump had also submitted Federal Tort Claims Act (FTCA) administrative claims for relief alleging an unlawful raid on his home, Mar-a-Lago, in Palm Beach, Florida, as well as unlawful targeting in relation to the infamous Russia-collusion hoax. Because President Trump is the Chief Executive, his lawsuits against the United States presented unique challenges. At the same time, Presidents do not forfeit their legal rights. Ultimately, the federal defendants agreed to resolve the litigation and pre-litigation FTCA administrative claims without the United States having to give the plaintiffs a "monetary payment or damages of any kind," as memorialized by a Settlement Agreement dated May 18, 2026. Instead, the plaintiffs would "receive a formal apology." The plaintiffs waived all claims that could have been asserted in connection with the litigation and administrative claims process. And the United States agreed to establish "a systematic process to hear and redress claims of others who, like Plaintiffs, state that they incurred harm from similar Lawfare and Weaponization" through "The Anti-Weaponization Fund." The Settlement Agreement states that the Attorney General, within 30 days of the settlement, would enter an order to "establish funding and any other relevant requirements, rules, conditions, terms, and waivers" and "issue an order appointing [five] Members, including the Chair." "One of the Members shall be chosen in consultation with congressional leadership," and all members would continue in their roles until the Fund concludes, "unless they resign or are removed by the President." The Members comprising the Fund would "have the power to determine its own procedures for submitting, receiving, processing, and granting or denying claims." The Settlement Agreement further states that the "Fund shall have the power to issue formal apologies, issue monetary relief owed to claimants as a result of their legal rights, grant claims in whole or in part, deny claims in whole or in part, defer review of claims, and receive and request evidence or other support for claims, including requesting information from, or consulting with, federal agencies." And "[o]n a quarterly basis, or otherwise as directed by the Attorney General, The Anti-Weaponization Fund shall provide to the Attorney General a confidential written report that includes the name and address of each claimant who has received any relief and if so, the nature of such relief." The Fund would "cease processing claims no later than December 1, 2028," and the Fund would "transfer [any remaining] balance . . . to the Department of Commerce, Interior, or another appropriate federal government account as designated by the President." On May 18, 2026, the Attorney General issued an order pursuant to the Settlement Agreement. On June 2, 2026, the Acting Attorney General testified at a congressional hearing that the United States was "not moving forward with the Fund, period" and confirmed "there's no more Fund." ARGUMENT I. PLAINTIFF'S CLAIMS ARE NOT JUSTICIABLE A. This Case Is Moot. This case is moot because "the issues presented are no longer live [and] the parties lack a legally cognizable interest in the outcome." Already, LLC v. Nike, Inc., 568 U.S. 85, 91 (2013). The Acting Attorney General's statements to Congress make it "absolutely clear the allegedly wrongful behavior could not reasonably be expected to recur." Id. B. Plaintiff Lacks Standing. In truth, this case has never presented an Article III Case or Controversy. Federal courts do not "operate as an open forum for citizens 'to press general complaints about the way in which government goes about its business.'" All. for Hippocratic Med., 602 U.S. at 379. C. Plaintiff's Claims Are Not Ripe For Adjudication. "[R]ipeness doctrine reflects the prudential concern that courts should not be forced to engage in adjudication divorced from any specific factual context." II. PLAINTIFF HAS NO LIKELIHOOD OF SUCCESS ON THE MERITS [Detailed analysis of APA claims, separation of powers arguments, and other substantive challenges — all fail for threshold justiciability reasons and on the merits.] CONCLUSION The Court should deny Plaintiff's motion for a temporary restraining order. Dated: June 5, 2026 STANLEY E. WOODWARD, JR. Associate Attorney General U.S. Department of Justice

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division ANDREW FLOYD, et al., Plaintiffs, v. DEPARTMENT OF JUSTICE, et al., Defendants. 1:26-cv-1399(LMB/IDD) ORDER Before the Court is plaintiffs' Expedited Motion for Briefing Schedule ("Expedited Motion"), which requests an expedited briefing and hearing schedule for its pending Motion for Temporary Restraining Order, Or in the Alternative, a Preliminary Injunction with Expedited Briefing and for a Stay Under 5 U.S.C. § 705 ("Motion"). See generally, [Dkt. No. 30]. Defendants oppose this Motion, requesting additional time to respond. See id. at 3-4. Because full briefing of the issue will enhance the ability of the Court to make a sound decision, plaintiffs' Expedited Motion, [Dkt. No. 30], is DENIED and defendants' request for additional time is GRANTED; however, to ensure that no funds are irreversibly disbursed from the Anti-Weaponization Fund (hereinafter, "Fund") while plaintiffs' Motion is pending, it is hereby ORDERED that defendants be and are ENJOINED from taking any further action pursuant to the creation or operation of the Anti-Weaponization Fund, which includes the transferring of money to the Fund; the consideration of any claims submitted to the Fund; and the disbursing of any funds from the Fund; It is important that the status quo be maintained until plaintiffs' pending Motion has been resolved, especially as plaintiffs allege in their Expedited Motion that defense counsel "was unable . . . to provide assurances of how long [the] status quo would last" and declined plaintiffs' request for an agreement to maintain the status quo. ORDERED that defendants file their Opposition to plaintiffs' Motion by close of business on Friday, June 5, 2026; and it is further ORDERED that plaintiffs file their Reply by close of business on Wednesday, June 10, 2026; and it is further ORDERED that the hearing on plaintiffs' Motion currently noticed for Friday, June 5, 2026, at 10:00 am be and is RESET to Friday, June 12, 2026 at 10:00 am. The Clerk is directed to forward a copy of this Order to counsel of record. Entered this 28th day of May, 2026. Alexandria, Virginia /s/ Leonie Brinkema United States District Judge

Trump Ordered to Respond to Motion to Reopen Case Against IRS MAY 29, 2026 Trump v. IRS UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PRESIDENT DONALD J. TRUMP, et al., Plaintiffs, v. INTERNAL REVENUE SERVICE, et al., Defendants. CASE NO. 1:26-cv-20609-KMW ORDER THIS MATTER is before the Court on the Motion to Reopen Case filed by thirty-five former federal judges ("Motion “) (DE 63). In the Motion, the non-party movants ask this Court to reopen the instant case pursuant to Rule 60 of the Federal Rules of Civil Procedure, arguing that the Court should "exercise its authority under Rule 60 to set aside the judgment in this lawsuit . . . [and] resume its inquiry into whether there is an actual underlying case or controversy[.]" (DE 63 at 6). The non-party movants explain that although there is no settlement of record in this matter, public documents and announcements indicate that the dismissal of this case was premised on a purported settlement between the Parties.1 In turn, movants submit that the settlement "is a product of collusion and is itself a fraud on the Court." (Id. at 9). A court is empowered to investigate serious misconduct as a collateral issue within the purview of Rule 11 and determine "whether an attorney has abused the judicial process." Didie v. Howes, 988 F.2d 1097, 1103 (11th Cir. 1993); see also Willy v. Coastal Corp. , 503 U.S. 131 (1992) (holding that a district court could impose Rule 11 sanctions even where it was subsequently determined to lack subject matter jurisdiction); Ormsby Motors, Inc. v. General Motors Corp., 32 F.3d 240, 241 (7th Cir. 1994) (finding that a litigant cannot avoid sanctions by voluntarily dismissing the case). Rule 11 issues can be "raised sua sponte by the [C]ourt." Meunier Carlin & Curfman, LLC v. Scidera, Inc. , 813 F. App’x 368, 375 (11th Cir. 2020); see also Taylor v. Stanciel, 202 F. App’x 662, 663-64 (5th Cir. 2006) (explaining that "a court may, on its own initiative, enter an order describing Rule 11 violations and ordering a party to show why it has not violated Rule 11"). “The purpose of Rule 11 is to deter baseless filings." Powrzanas v. Jones Util. & Contracting Co. , 834 F. App’x 500, 507 (11th Cir. 2020). Specifically, Rule 11 "requires that an attorney or unrepresented party filing a pleading certify that the filing is not presented for any improper purpose." Id. (internal quotation marks omitted); see also In re Ames , 993 F.3d 27, 34 (1st Cir. 2021) ("Under Rule 11, a court may impose sanctions on a lawyer ‘for advocating a frivolous position, pursuing an unfounded claim, or filing a lawsuit for some improper purpose.’") (emphasis added). A party’s decision to file a frivolous lawsuit for the sole purpose of forcing a settlement may qualify as such an improper purpose. See Scott v. Vantage Corp., 64 F.4th 462, 472 (3d Cir. 2023) (afrming the district court’s finding that plaintifs filed their complaint for an improper purpose when two out of the three claims lacked factual support and plaintifs expressed that they filed the lawsuit to force a settlement). If a party files a lawsuit for an improper purpose, "the court may impose an appropriate sanction on the responsible party." Powrzanas , 834 F. App’x at 507. Here, the non-party movants advance grievous allegations that Plaintifs voluntarily dismissed this litigation solely to avoid judicial scrutiny of a lawsuit that "was collusive from the start" and was only filed to provide the imprimatur of legality for an unlawful settlement. (DE 63 at 16). They point to the fact that the settlement in question includes a "three-paragraph addendum2 . . . [that] purports to ‘forever bar[ ] and preclude[ ]’ the United States from pursuing claims that could have been [otherwise] asserted [against] Plaintifs," (Id. at 8), and highlight the fact that Defendants did not "even try[ ] to defend against Plaintifs’ claims" despite their active opposition to nearly identical claims in other litigation.3 (Id. at 16). Finally, the non-party movants assert that Plaintifs’ claims were "clearly untimely" and therefore untenable. (Id. ). Accordingly, it is ORDERED AND ADJUDGED that Plaintifs shall file a response to the Motion (DE 63) on or before June 12, 2026, detailing their position on the matters set forth in the Motion, including (1) the charges of collusion and whether the Parties are truly adverse; (2) the assertion that the dismissal in this case was premised on deception by the Parties; and (3) the question of whether the case should be reopened because the Court was the "victim of a fraud." (DE 63 at 13, citing 11 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure §2870 (3d ed.)). The non-party movants may, if they choose, file a reply on or before June 19, 2026. DONE AND ORDERED in Chambers in Miami, Florida, on this 29th day of May, 2026. KATHLEEN M. WILLIAMS UNITED STATES DISTRICT JUDGE FOOTNOTES 1. As the Court noted in its April 29, 2026 Order (DE 43), Defendants did not file any notices of appearances and acted through Plaintifs to ask the Court for relief from their imminent answer deadline. 2. This addendum, as the non-party movants point out, may be in conflict with internal Department of Justice policies that require the Department to only enter into compromises that are "specifically limited to the immediate subject matter of the claim which was in fact compromised." (DE 63 at 8). The addendum was signed only by the Acting Attorney General. 3. The Court is aware of reporting that the IRS prepared a memorandum outlining ways to challenge Plaintifs’ claims. Andrew Duehren, The I.R.S. Thought It Could Fight Trump’s Lawsuit, but It Struck a Deal Anyway , N.Y. Times (May 19, 2026), https:// www.nytimes.com/2026/05/19/admin/irs-trump-lawsuit-deal.html. These defenses are consistent with the positions taken by the IRS and the Department of Justice in other litigation.

COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON, Plaintiff, v. U.S. DEPARTMENT OF JUSTICE; TODD BLANCHE, in his official capacity as Acting Attorney General; U.S. DEPARTMENT OF THE TREASURY; SCOTT BESSENT, in his official capacity as Secretary of the Treasury; INTERNAL REVENUE SERVICE; FRANK BISIGNANO, in his official capacity as Chief Executive Officer of the Internal Revenue Service; THE ANTI-WEAPONIZATION FUND; J. DOES 1–5, in their official capacities as Members of the Anti-Weaponization Fund, Defendants. Case No. 26-cv-1789 INTRODUCTION 1. On May 18, President Trump executed a collusive settlement of Trump v. IRS, No. 26-cv-20609 (S.D. Fla.), a lawsuit he filed against two federal agencies he controls. Engineered by the President's political appointees, the sham settlement created a new slush fund designed to funnel $1.776 billion in taxpayer dollars from the Treasury's Judgment Fund to purported victims of what the President considers "lawfare" and government "weaponization" ("the Slush Fund" or "the Fund"). 2. The Slush Fund is a jaw-dropping act of presidential corruption. And it is brazenly illegal. Unlike prior victim compensation funds, it was not authorized by Congress. Nor was the Fund the product of a judicially approved, arm's length legal settlement. It was created solely by Executive fiat, an unconstitutional taxpayer-funded giveaway to the President's allies that is wholly untethered from the claims asserted in Trump v. IRS. Among the Fund's expected beneficiaries are throngs of insurrectionists who brutally attacked police officers and stormed the U.S. Capitol to halt the transfer of presidential power on January 6, 2021, and who were later pardoned by President Trump. 3. The Fund's charter documents — a May 18 settlement agreement and incorporated order of the Acting Attorney General (together, "the Slush Fund Order") — instruct that the $1.776 billion in taxpayer funds will be doled out by five "Members" appointed by the Attorney General and removable solely by President Trump. The Fund's members shall have final, unreviewable authority to "issue monetary relief" that they alone decide is "owed to claimants." [FACTUAL ALLEGATIONS — Summary] Background 4–19. [Historical background on the Trump v. IRS lawsuit, including Littlejohn's criminal conduct, the IRS's receipt of criminal charges notice, similar prior litigation, and the genesis of the lawsuit.] Trump and His Family File a Meritless Lawsuit Against the Administration He Controls 60–67. [Facts regarding the Trump v. IRS complaint, the court's Article III concerns, the court-appointed amici brief, and the collusive settlement.] Establishment and Terms of the Slush Fund 68–120. [Detailed facts regarding the structure, funding, and design of the Anti-Weaponization Fund, including that it is funded with $1.776 billion from the Judgment Fund; creates five Members appointed by the AG and removable by the President; has procedures that need not be made public; will not be subject to judicial review; and whose payments and claimant identities will be kept secret.] 71. The dollar amount $1.776 billion deliberately invokes the year 1776, framing the fund as a patriotic and revolutionary enterprise and echoing a rallying call among January 6 participants. Defendants' Illegal Conduct Has Injured CREW 121–139. [Facts regarding CREW's organizational standing, informational injury under FOIA, and other harms.] CLAIMS FOR RELIEF Count I — Violation of the Appropriations Clause (U.S. Const. Art. I, § 9, cl. 7) Count II — Violation of the Separation of Powers Count III — Violation of the APA — Arbitrary and Capricious Count IV — Violation of the APA — Contrary to Law Count V — Violation of FOIA Count VI — Violation of the Federal Records Act Count VII — Violation of the Domestic Emoluments Clause (U.S. Const. Art. II, § 1, cl. 7) PRAYER FOR RELIEF Plaintiffs respectfully request that this Court declare the Anti-Weaponization Fund and its enabling documents unconstitutional and unlawful; enjoin Defendants from establishing, operating, or funding the Anti-Weaponization Fund; compel compliance with FOIA and the FRA; and award attorneys' fees, costs, and such other and further relief as the Court deems just and proper. Filed: May 22, 2026

COMPLAINT IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA HARRY A. DUNN and AQUILINO GONELL and MICHAEL FANONE and DANNY HODGES, Plaintiffs, v. DONALD J. TRUMP, in his official capacity as President; TODD BLANCHE, in his official capacity as Acting Attorney General; SCOTT BESSENT, in his official capacity as Secretary of the Treasury; and FRANK BISIGNANO, in his official capacity as Commissioner of the Internal Revenue Service, Defendants. Case No. 1:26-cv-01719 INTRODUCTION 1. Plaintiffs Harry Dunn, Aquilino Gonell, Michael Fanone, and Danny Hodges are United States Capitol Police officers who, on January 6, 2021, were brutally assaulted while defending the United States Capitol against a violent mob that sought to prevent the certification of the 2020 presidential election. They suffered serious bodily harm — including traumatic brain injuries, cracked ribs, a crushed spinal disc, and deep lacerations — along with severe and lasting psychological trauma. 2. On May 18, 2026, Defendants created the Anti-Weaponization Fund, purporting to provide "a systematic process to hear and redress claims of others who, like [the Trump v. IRS plaintiffs], state that they incurred harm from similar Lawfare and Weaponization." According to Defendants, the Fund defines eligible "Lawfare and Weaponization" as "the sustained use of the levers of government power by Democrat elected officials, political and career federal employees, contractors, and agents in order to target individuals, groups, and entities for improper and unlawful political, personal, and/or ideological reasons." 3. By expressly limiting eligibility to victims of "Democrat" actors, the Anti-Weaponization Fund is designed to benefit Trump's political allies — including those convicted for their roles on January 6, 2021 — while excluding victims of Republican-orchestrated abuses of power. This is precisely what Defendants have done: They have engineered the Fund to benefit January 6 rioters — many of whom were convicted of violent crimes and then pardoned by President Trump — while excluding police officers like Plaintiffs, who were brutally attacked by those same rioters. [FACTUAL ALLEGATIONS] The January 6, 2021 Assault on the Capitol and Its Aftermath 4–20. Detailed facts regarding each officer plaintiff's service, the January 6 attack, the injuries they sustained, and the threats and harassment they received following the attack. 21. In total, approximately 140 police officers were injured on January 6, 2021. Among those injured were each of the Plaintiffs. The Trump-Vance Administration's Efforts to Benefit January 6 Participants at Plaintiffs' Expense 22–50. Detailed facts regarding President Trump's repeated defense of January 6 participants, his pardons of January 6 rioters (including those convicted of violent crimes), and the harassment and threats Plaintiffs received from Trump supporters in connection with his statements. Trump Filed a Frivolous Lawsuit Against His Own Administration 51–68. Detailed facts regarding the Trump v. IRS lawsuit, its lack of adverseness, and the collusive settlement that created the Anti-Weaponization Fund. Defendants Purported to Create and Fund the Anti-Weaponization Fund 76–105. Detailed facts regarding the structure, funding, and design of the Anti-Weaponization Fund, including that it is funded with $1.776 billion from the Judgment Fund, is explicitly limited to alleged victims of "Democrat" officials, excludes victims of Republican-orchestrated abuses of power, and was designed without congressional authorization. CLAIMS FOR RELIEF Count I — Violation of the Equal Protection Component of the Fifth Amendment Due Process Clause Count II — Violation of the First Amendment Count III — Violation of the Appropriations Clause PRAYER FOR RELIEF Plaintiffs respectfully request that the Court: (1) declare the Anti-Weaponization Fund unconstitutional; (2) enjoin Defendants from establishing, operating, or funding the Anti-Weaponization Fund; (3) award Plaintiffs their attorneys' fees and costs; and (4) grant such other and further relief as the Court deems just and proper. Filed: May 20, 2026

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. 1:26-cv-20609-KMW PRESIDENT DONALD J. TRUMP, DONALD J. TRUMP JR., ERIC TRUMP, AND THE TRUMP ORGANIZATION, LLC, Plaintiffs, v. INTERNAL REVENUE SERVICE AND U.S. DEPARTMENT OF THE TREASURY, Defendants. PLAINTIFFS' NOTICE OF VOLUNTARY DISMISSAL WITH PREJUDICE PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 41(a)(1)(A)(i) Plaintiffs President Donald J. Trump, Donald J. Trump Jr., Eric Trump, and The Trump Organization, LLC (collectively, "Plaintiffs"), by and through undersigned counsel, hereby give notice of the voluntary dismissal of this action with prejudice pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). Defendants Internal Revenue Service and the United States Department of the Treasury have neither served an answer nor a motion for summary judgment in this action. Accordingly, voluntary dismissal under Rule 41(a)(1)(A)(i) is available as of right, and requires neither leave of Court nor the consent of any party. LEGAL FRAMEWORK Rule 41(a)(1)(A)(i) dismissals are self-executing and effective immediately upon filing. The Eleventh Circuit has established that such dismissals terminate the action upon filing and divest the district court of jurisdiction. Key legal precedents cited: - Matthews v. Gaither, 902 F.2d 877, 880 (11th Cir. 1990) - Anago Franchising, Inc. v. Shaz, LLC, 677 F.3d 1272, 1277-78 (11th Cir. 2012) - W. Grp. Nurseries, Inc. v. Ergas, 167 F.3d 1354, 1358 (11th Cir. 1999) - University of S. Ala. v. Am. Tobacco Co., 168 F.3d 405, 409 (11th Cir. 1999) COSTS AND FEES Each party shall bear its own attorneys' fees and costs. Dated: May 18, 2026 Filed by: BRITO, PLLC 2121 Ponce de Leon Boulevard Suite 650 Coral Gables, FL 33134 Lead Counsel: Alejandro Brito, Florida Bar No. 098442 — [email protected] Daniel Z. Epstein, D.C. Bar No. 1009132 — EPSTEIN & CO. LLC — [email protected]

MEMORANDUM OF COURT-APPOINTED AMICI CURIAE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO. 1:26-cv-20609-WILLIAMS/LETT PRESIDENT DONALD J. TRUMP, et al., Plaintiffs, v. INTERNAL REVENUE SERVICE, et al., Defendants. INTERESTS OF AMICI CURIAE In its Order dated April 24, 2026, the Court indicated that it "has concerns about whether it has subject matter jurisdiction in this case" and appointed undersigned counsel "to assist the Court in identifying the applicable law governing an analysis of this issue." Dkt. No. 43. Amici accordingly submit this memorandum in support of neither party in an effort to aid the Court in determining whether jurisdiction lies in this case. INTRODUCTION The Framers "vested" the 'judicial Power of the United States' in the federal courts, but they limited those courts' jurisdiction. U.S. Const. art. III, § 1. Article III of the United States Constitution constrains the circumstances in which the federal courts may act and the types of matters they may consider. One such constraint is the requirement that there be a genuine "Case" or "Controversy" — which requires, among other things, that the parties be truly adverse to each other. This case is unprecedented: A sitting president seeks monetary damages for alleged harm to his personal interests from an executive agency that he controls. That presents significant Article III subject matter jurisdiction concerns. There is also reason to believe that the President is, in fact, exercising his control over the Defendants in this litigation. ANALYSIS I. Adversity Between the Parties Is Essential to Article III Jurisdiction. The Constitution empowers federal courts to hear only "Cases" and "Controversies." Courts have long held that adversity between the parties is essential to jurisdiction — a court cannot decide a case in which one party controls both sides of the litigation. The Supreme Court has recognized that a judgment would lack the requisite adversarial testing if one party "controls the conduct of litigation on both sides." United States v. Interstate Com. Comm'n, 337 U.S. 426, 430 (1949). II. Determining Whether Adversity Exists Requires a Fact-Specific Analysis. A. The Relationship Between the Parties. Adversity analysis is a practical and functional inquiry that looks beneath the formalities of the caption to examine one party's capacity to exercise control over the other. As President, Mr. Trump is the Chief Executive and possesses constitutional authority over all executive branch officials. The Secretary of Treasury is a cabinet official whom the President may remove at will. The IRS Commissioner is also removable at the will of the President. And President Trump has shown he is willing to exercise that authority — in August 2025, two months after IRS Commissioner Billy Long's confirmation, President Trump removed him without providing a reason. The President also has tremendous control over DOJ. Executive Order 14215, "Ensuring Accountability for All Agencies," 90 Fed. Reg. 10447 (Feb. 18, 2025), provides that "the President and the Attorney General, subject to the President's supervision and control, shall provide authoritative interpretations of law for the executive branch." The President's "opinions on questions of law are controlling on all employees in the conduct of their official duties." There is also reason to believe that the President is, in fact, exercising his control over the Defendants in this litigation. President Trump's own statements suggest that he believes he has control over the Defendants and the DOJ lawyers charged with defending this case. On January 31, 2026, two days after President Trump filed the Complaint, a reporter asked him "what it's like to be on both sides of a lawsuit." He responded: "It's very interesting. I have another one where, you know, I virtually won the Mar-a-Lago break-in suit, and, you know, I have to work out some kind of a settlement. I'm supposed to work out a settlement with myself." The contrast between Defendants' conduct here and the government's conduct in related litigation also suggests that the President may have control over DOJ's litigation conduct. The parties are engaged in settlement negotiations in this case, even though DOJ has asserted substantial defenses in other cases stemming from Mr. Littlejohn's disclosures of tax information — including cases litigated during President Trump's current term. B. Effects of the Court's Order. Even where one party controls the other, adversity may exist if the court can enter an order with real-world effect. Here, the case was filed on January 29, 2026, and Defendants have not yet indicated whether they will defend against this suit. III. Considerations Relevant to Determining Adversity in this Case. A. The Relationship Between the Parties. The President's capacity for control over these Defendants is extraordinary. As a member of the President's cabinet, the Secretary of the Treasury "is and must be the President's alter ego in the matters of that department." The IRS Commissioner is likewise removable at will. And the Attorney General is a cabinet official whom the President may remove at will. B. The Effect of the Court's Order. To the extent the Court reaches this part of the analysis, the adversity inquiry likely cannot be concluded at this time. It is insufficiently clear that the Court would be unable to enter an order with real effect. Defendants have not taken any positions in this litigation yet. C. Potential Additional Areas of Inquiry. If the Court allows the case to proceed, it may choose to seek the input of an amicus on the merits. Notably, however, if the Court concludes that adversity is lacking — either at the outset or later on, based on parties' future litigation conduct — appointment of an amicus would not cure that deficiency. Article III "demands that an 'actual controversy' persist throughout all stages of litigation." Hollingsworth v. Perry, 570 U.S. 693, 705 (2013). CONCLUSION Amici remain at the Court's disposal to provide additional analysis of issues raised in the parties' submissions or by other developments in the case. Dated: May 14, 2026 Respectfully submitted, SELENDY GAY PLLC · Faith E. Gay (Fla. Bar #129593) DEBEVOISE & PLIMPTON LLP · John Gleeson; David A. O'Neil MUNGER TOLLES & OLSON LLP · Donald B. Verrilli, Jr. Court-Appointed Amici Curiae

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA CITIZENS FOR RESPONSIBILITY AND ETHICS IN WASHINGTON, P.O. Box 14596 Washington, DC 20044, Plaintiff, v. U.S. DEPARTMENT OF JUSTICE, 950 Pennsylvania Avenue NW Washington, DC 20530, Defendant. Civil Action No. 1:26-cv-01163 COMPLAINT 1. Plaintiff Citizens for Responsibility and Ethics in Washington ("CREW") brings this action under the Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, seeking records from the Department of Justice ("DOJ") Civil Division ("Civil Division") concerning President Donald Trump's attempt to seek a financial windfall from American taxpayers by abusing the Federal Tort Claims Act ("FTCA"). 2. President Donald Trump's course of conduct relating to the 2020 presidential election, culminating in his incitement of a violent insurrection to halt the lawful transfer of power on January 6, 2021, and his later retention of classified documents after leaving office, triggered multiple criminal investigations by the DOJ and FBI. These investigations led two grand juries to return indictments charging President Trump with 44 federal criminal counts. 3. DOJ moved to dismiss all criminal charges against President Trump after his reelection in 2024, due to DOJ policy forbidding the prosecution of a sitting president. 4. Before his re-election, President Trump reportedly submitted two FTCA complaints to the DOJ seeking approximately $230 million in damages related to his federal criminal prosecutions. 5. Now that he has been re-elected, President Trump's FTCA complaints pose an unprecedented and unavoidable conflict of interest, as his entitlement to a tax-payer funded windfall will be evaluated by his own administration, staffed by his former personal attorneys. 6. On November 18, 2025, CREW submitted an expedited FOIA request to the Civil Division seeking records related to President Trump's administrative claims for relief under the FTCA, as well as copies of any final approval, denial, or request for reconsideration of any claim filed by or on behalf of the president. 7. CREW now seeks declaratory and injunctive relief requiring DOJ to process CREW's FOIA request, preserve all records potentially responsive to CREW's requests, and expeditiously disclose the requested records. JURISDICTION AND VENUE 8. This Court has subject-matter jurisdiction and personal jurisdiction pursuant to 5 U.S.C. §§ 552(a)(4)(B) and 552(a)(6)(E)(iii). The Court also has jurisdiction over this action under 28 U.S.C. §§ 1331, 2201(a), and 2202. 9. Venue lies in this district under 5 U.S.C. § 552(a)(4)(B) and 28 U.S.C. § 1391(b). PARTIES 10. Plaintiff CREW is a non-profit, non-partisan organization organized under section 501(c)(3) of the Internal Revenue Code. CREW is committed to protecting the rights of citizens to be informed about the activities of government officials and agencies, and to ensuring the integrity of government officials and agencies. CREW seeks to empower citizens to have an influential voice in government decisions and in the government decision-making process through the dissemination of information about public officials and their actions. To advance its mission, CREW uses a combination of research, litigation, and advocacy. As part of those efforts, CREW uses government records it obtains under FOIA. 11. Defendant DOJ is an agency within the meaning of 5 U.S.C. § 552(f)(1). DOJ has possession and control of the records requested by CREW and is responsible for fulfilling CREW's FOIA requests. LEGAL FRAMEWORK 12. FOIA, 5 U.S.C. § 552, requires federal agencies to release requested records to the public unless one or more specific statutory exemptions apply. 13. An agency must respond to a party making a FOIA request within 20 business days and, in so doing, must notify the party of at least the agency's "determination" of which requested records it will release, which it will withhold and why, and the requester's right to appeal the determination to the agency head. Id. § 552(a)(6)(A)(i); see, e.g., CREW v. FEC, 711 F.3d 180, 187 (D.C. Cir. 2013). 14. An agency's failure to make this determination within 20 days is subject to judicial review without exhausting administrative remedies. 5 U.S.C. § 552(a)(6)(C)(i). 15. Moreover, FOIA provides that "each agency, upon any request for records which (i) reasonably describes such records and (ii) is made in accordance with published rules . . . shall make the records promptly available to any person." 5 U.S.C. § 552(a)(3)(A). 16. After a FOIA request is received by an agency, it must "make reasonable efforts to search for the records." 5 U.S.C. § 552(a)(3)(C). If the agency identifies any responsive records, the agency must make them "promptly available." Id. § 552(a)(3)(A). 17. In "unusual circumstances," the 20 business day time limit "may be extended" by 10 business days if the agency provides "written notice to the person making such request setting forth the unusual circumstances for such extension and the date on which a determination is expected to be dispatched." 5 U.S.C. § 552(a)(6)(B)(i). "[U]nusual circumstances means," among other things, "the need to search for and collect the requested records from field facilities or other establishments that are separate from the office processing the request." Id. § 552(a)(6)(B)(iii). 18. Further, agencies must grant requests for expedited processing of FOIA requests when requesters demonstrate a "compelling need," as well as in "other cases determined by the agency." 5 U.S.C. § 552(a)(6)(E)(i). "Compelling need" requires the requester to show that they are "a person primarily engaged in disseminating information" with an "urgency to inform the public concerning actual or alleged Federal Government activity." Id. § 552(a)(6)(E)(v)(II); see also 28 C.F.R. § 16.5(e)(1)(ii). 19. Defendant's FOIA regulations also require expedited processing for other reasons, including "[a] matter of widespread and exceptional media interest in which there exist possible questions about the government's integrity that affect public confidence." See 28 C.F.R. § 16.5(e)(1)(iv). 20. A determination of whether to provide expedited processing shall be made, and notice of the determination shall be provided to the person making the request, within 10 calendar days after the date of the request. 5 U.S.C. § 552(a)(6)(E)(ii)(I). 21. Agency action to deny a request for expedited processing, or failure by an agency to respond in a timely manner to such a request, is subject to judicial review. 5 U.S.C. § 552(a)(6)(E)(iii). 22. FOIA requesters who do not receive a determination on a request for expedited processing within 10 calendar days, or who receive a decision denying or affirming the denial of a request for expedited processing, also may seek immediate judicial review. See, e.g., 5 U.S.C. § 552(a)(6)(E)(iii). FACTUAL ALLEGATIONS 23. On January 6, 2021, a violent mob incited by President Trump attacked the United States Capitol to stop the constitutionally mandated transfer of presidential power following the 2020 election. The attack injured more than 100 law enforcement officers, killed at least one, and forced the Vice President and other lawmakers to flee for their lives. The mob temporarily stopped the counting of electoral votes mandated by the Twelfth Amendment. See Anderson v. Griswold, 543 P.3d 283, 329 (Colo. 2023), rev'd on other grounds sub nom. Trump v. Anderson, 601 U.S. 100 (2024) (per curiam). 24. Trump had motivated the mob to come to Washington D.C. by lying about election fraud over the course of the 2020 election cycle and incited the crowd to violence during a speech at the White House Ellipse that morning, knowing that many in the crowd were armed and prepared for violence. He continued to incite the mob even after learning that the Capitol was under violent attack and refused repeated calls to send reinforcements to the Capitol or to call off the mob. Id. 25. On January 20, 2021, Trump begrudgingly left office after failing to thwart the constitutional transfer of power to his successor. 26. Upon leaving office, Trump had cardboard boxes full of highly sensitive classified documents transported to his Mar-a-Lago Club in Florida. He had the documents stored in various unsecured locations around the club, including in a ballroom and a bathroom. See Superseding Indictment, United States v. Trump, et al., No. 9:23-cr-80101-AMC (S.D. Fla. July 27, 2023). 27. Trump's engagement in insurrection and mishandling of classified information triggered multiple criminal investigations by DOJ and FBI. 28. In 2022, then-Attorney General Merrick Garland appointed a Special Counsel to oversee these investigations and prosecute any individual found to have committed federal crimes. See Off. of the Att'y Gen., Order No. 5559-2022, Appointment of John L. Smith as Special Counsel (Nov. 18, 2022). 29. The Special Counsel's investigations led two grand juries to find probable cause for indictments, charging President Trump with 44 criminal counts. The charges included conspiracy to defraud the United States, obstructing an official proceeding, conspiracy against rights, willful retention of national security material, and obstruction of justice. See Superseding Indictment, United States v. Trump, et al., No. 9:23-cr-80101-AMC (S.D. Fla. July 27, 2023); Indictment, United States v. Trump, No. l:23-cr-00257-TSC (D.D.C. August 1, 2023). 30. On November 5, 2024, President Trump won re-election to the presidency. 31. On November 25, 2024, after consulting the Department's Office of Legal Counsel, the Special Counsel moved to drop all charges against Donald Trump, citing DOJ policy that it does not prosecute sitting presidents of the United States. See Gov'ts Mot. to Dismiss, United States v. Trump, No. l:23-cr-00257-TSC (D.D.C. Nov. 25, 2024); Gov'ts Mot. to Dismiss Appeal, United States v. Trump, No. 24-12311-J (11th Cir. Nov. 25, 2024). 32. In 2023 and 2024, as a private citizen, President Trump reportedly filed at least two administrative claims with the DOJ seeking damages for purported violations of his rights relating to investigations of his potentially criminal conduct. [Footnote 1: Devlin Barrett & Tyler Pager, Trump Said to Demand Justice Dept. Pay Him $230 Million for Past Cases, N.Y. Times (Oct. 21, 2025), https://www.nytimes.com/2025/10/21/us/politics/trump-justice-department-compensation.html.] 33. FTCA settlements are paid out of appropriated federal funds. See 31 U.S.C. § 1304. 34. President Trump, in his role as chief executive of the United States, now oversees the DOJ and has appointed its senior leadership, including the individuals charged with reviewing and potentially approving the president's administrative claims. 35. The Justice Manual states that, generally, an Assistant Attorney General can "compromise (or settle administratively) a defense claim when the principal amount of the proposed settlement does not exceed $4 million," and that "the Deputy Attorney General or Associate Attorney General, as appropriate, is further specifically authorized to exercise the settlement authority of the Attorney General as to all affirmative and defensive civil claims." DOJ, Just. Manual § 4-3.110 (2020). 36. Deputy Attorney General Todd Blanche and Associate Attorney General Stanley Woodward each previously served as criminal defense counsel in cases involving President Trump, with Associate Attorney General Woodward representing President Trump's personal aide Walt Nauta in the classified documents prosecution that serves as the basis for at least one of the President's administrative claims. 37. On November 18, 2025, CREW submitted a FOIA request to the Civil Division seeking the following records created after January 20, 2021 to the date the requests are processed: a. Any Standard Form 95 or other document asserting an administrative claim for relief under the Federal Tort Claims Act ("FTCA"), 28 U.S.C. §§ 2671-2680, submitted by or on behalf of President Donald Trump pursuant to 28 C.F.R. § 14.2, including all documentation, exhibits, affidavits, and evidence submitted with such claims. b. Any final denial, issued pursuant to 28 C.F.R. § 14.9(a), of an administrative claim for relief under the FTCA submitted by or on behalf of President Trump, including the statement of reasons for the denial and any other accompanying documentation. c. Any request for reconsideration of a final denial of any FTCA claim filed by or on behalf of President Trump pursuant to 28 C.F.R. § 14.9(b). d. Any document memorializing an award, compromise, or settlement, made pursuant to 28 C.F.R. § 14.10, on any FTCA claim submitted by or on behalf of President Trump, including records sufficient to identify the amount of any payment, any copy of Standard Form 1145 sent to the General Accounting Office, any evidence of approval of a payment by the Attorney General or his or her designee, and any other accompanying documentation. e. All communications related to the processing, initial consideration, denial, approval, or appeal for reconsideration of any FTCA claim filed by or on behalf of President Trump pursuant to 28 C.F.R. § 14.2. See Ex. A. 38. The Civil Division acknowledged receipt of the FOIA request via an automated message on November 18, 2025. 39. On January 28, 2026, CREW emailed the Civil Division requesting an update on CREW's FOIA request. 40. CREW has received no response to its email and has received no other correspondence from the Civil Division concerning its November 18, 2025 FOIA request to date. CLAIMS FOR RELIEF COUNT I VIOLATION OF FOIA - WRONGFUL WITHHOLDING OF RECORDS (5 U.S.C. § 552) 41. CREW re-alleges and incorporates by reference the foregoing paragraphs. 42. In its November 18, 2025 request, CREW properly sought records within the possession, custody, and control of Defendant. 43. Defendant is wrongfully withholding records responsive to CREW's FOIA requests by failing to make determinations on CREW's requests within the statutorily prescribed period of 20 business days, as required by 5 U.S.C. 552(a)(6)(A), and by continuing to withhold documents that are non-exempt and responsive to CREW's FOIA requests. 44. Defendant has failed to conduct an adequate search in response to CREW's FOIA requests. 45. CREW has constructively exhausted its administrative remedies. 46. CREW is therefore entitled to injunctive and declaratory relief requiring the processing and disclosure of all non-exempt requested records to CREW. COUNT II VIOLATION OF FOIA - FAILURE TO GRANT EXPEDITED PROCESSING (5 U.S.C. § 552) 47. CREW re-alleges and incorporates by reference the foregoing paragraphs. 48. In its November 18, 2025 FOIA request, CREW properly sought expedited processing of these requests seeking records within the possession, control, and custody Defendant. 49. CREW properly sought expedited processing from Defendant because of the urgency to inform the public about an actual or alleged federal government activity and because CREW is primarily engaged in disseminating information. 50. CREW further properly sought expedited processing from Defendant because the subject of the requests concerns a matter of widespread and exceptional media interest in which there exist possible questions about the government's integrity that affect public confidence. See 28 C.F.R. § 16.5. 51. Defendant wrongfully denied CREW's requests for expedited processing by failing to respond to CREW's expedited processing requests within 10 days and failing to process CREW's requests on an expedited basis. 52. By denying CREW's requests for expedited processing and failing to expeditiously process and release all requested non-exempt records to CREW, Defendant is in violation of FOIA and its implementing regulations. 53. CREW is therefore entitled to injunctive and declaratory relief requiring expedited processing of its November 18th, 2025 request. REQUEST FOR RELIEF WHEREFORE, CREW respectfully requests that this Court: (1) Order Defendant to preserve all records, in whatever form they exist, potentially responsive to CREW's November 18, 2025 request prior to and during the processing of its request; (2) Declare that CREW is entitled to expedited processing of its FOIA request; (3) Order Defendant to immediately and fully process CREW's FOIA request and expeditiously disclose all non-exempt responsive records to CREW; (4) Order Defendant to grant CREW's request for a fee waiver; (5) Provide for expeditious proceedings in this action; (6) Retain jurisdiction of this action to ensure no agency records are wrongfully withheld and ensure compliance with this Court's orders; (7) Award CREW its costs and reasonable attorneys' fees in this action; and (8) Grant such other relief as the Court may deem just and proper. Date: April 6, 2026 Respectfully submitted, /s/ Kayvan Farchadi Kayvan Farchadi (D.C. Bar No. 1672753) Citizens for Responsibility and Ethics in Washington P.O. Box 14596 Washington, DC 20044

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 26-cv-20609-WILLIAMS/LETT PRESIDENT DONALD J. TRUMP, et al., Plaintiffs, v. INTERNAL REVENUE SERVICE, et al., Defendants. MOTION FOR LEAVE TO FILE BRIEF AS AMICI CURIAE BY FORMER GOVERNMENT OFFICIALS AND PUBLIC INTEREST ORGANIZATIONS INTRODUCTION Four former government officials, along with the nonpartisan organizations Common Cause and Project On Government Oversight, respectfully submit this motion for leave to file a brief as amici curiae, attached as Exhibit A. Collectively, amici curiae have decades of experience in federal tax law and in defending the Constitution, the rule of law, and the interests of the American people. Amici respectfully submit this brief to present to the Court the interests of taxpayers in this lawsuit, which was filed by the President, two of his sons, and their family business seeking "at least" $10 billion from the U.S. Treasury for alleged unauthorized disclosures of tax return information and alleged Privacy Act violations. INTERESTS OF AMICI John Koskinen served as the 48th Commissioner of the Internal Revenue Service. He was confirmed to the position by the Senate in 2013, and he served in the position until 2017. Prior to his service as IRS Commissioner, he served in a number of positions in the public and private sector, including as the non-executive chairman of the Federal Home Loan Mortgage Corporation (Freddie Mac) from 2008 to 2012. Kathryn Keneally served as the Assistant Attorney General for the U.S. Department of Justice's Tax Division. She was confirmed to the position by the Senate in 2012, and she served in the position until 2014. Prior to her service in the Department of Justice, she practiced tax law in private practice for thirty years and served as chair of the American Bar Association's Section of Taxation's Committees on Civil and Criminal Tax Penalties and Standards of Tax Practice. Nina Olson served as the National Taxpayer Advocate from 2001 to 2019. In that role, she led the Taxpayer Advocate Service, an independent organization within the Internal Revenue Service. Prior to serving in that role, she had over two decades of experience representing individual taxpayers at all levels of income. Gilbert Rothenberg served as the Chief of the U.S. Department of Justice, Tax Division, Appellate Section. He joined the Department as a line attorney in the Appellate Section in 1975 and served in the Section until his retirement in 2019. Common Cause is a nonpartisan, grassroots organization dedicated to upholding the core values of American democracy by working to create open, honest, and accountable government that serves the public interest. Common Cause has over 1.5 million members nationwide and local organizations in 23 states. Project On Government Oversight (POGO) is a nonpartisan, independent watchdog that investigates, exposes, and champions reforms on systemic corruption, abuse of power, and waste. POGO envisions a federal government that is effective and accountable—governed by just laws, operating with integrity, and committed to serving the public. Government ethics and public trust in the federal government are at the heart of POGO's mission. ARGUMENT District courts possess the inherent authority to allow amici to assist in their proceedings. In re Bayshore Ford Trucks Sales, Inc., 471 F.3d 1233, 1249 n.34 (11th Cir. 2006); Resort Timeshare Resales, Inc. v. Stuart, 764 F. Supp. 1495, 1500 (S.D. Fla. 1991). Because an amicus "participates only for the benefit of the court, it is solely within the discretion of the court to determine the fact, extent, and manner of participation by the amicus." Resort Timeshare, 764 F. Supp. at 1501. This Court should grant this motion for leave to file an amicus brief by former government officials, Common Cause, and POGO because the President currently controls both sides of the litigation. On the Plaintiffs' side, he is the lead plaintiff, alongside his family members and his family business, and on the government side, the President has asserted control over litigation decisions by the Department of Justice. See, e.g., Exec. Order No. 14215, § 7, 90 Fed. Reg. 10447, 10448 (Feb. 24, 2025); Memorandum for All Department Employees from the Attorney General, Re: General Policy Regarding Zealous Advocacy on Behalf of the United States (Feb. 5, 2025), https://perma.cc/8C3W-A5BZ. As the President himself stated in comments he made to the press, "I'm supposed to work out a settlement with myself." White House, President Trump Gaggles with Press on Air Force One En Route Palm Beach, FL, at 02:40 (Jan. 31, 2026), https://www.youtube.com/live/IvgGnWcxRhE. In another interview, the President stated: "Essentially, the lawsuit's been won. I guess I won a lotta money. . . . [T]here's never been anything like it." Read the extended transcript: President Donald Trump interviewed by 'NBC Nightly News' anchor Tom Llamas, NBC News (Feb. 4, 2026), https://perma.cc/988K-AGAM. Because of these conflicts of interest, there is legitimate reason for concern that neither Plaintiffs nor Defendants may make the arguments that adversarial parties typically would make in cases like this, including arguments the government has made in similar cases. See, e.g., U.S. Mot. to Dismiss 1, Safe Harbor Int'l, LLC v. IRS, No. 25-cv-00139 (D. Md. July 23, 2025), ECF No. 31. Courts routinely grant leave to file an amicus brief where the amicus "'contribute[s] to the court's understanding of the matter in question' by proffering timely and useful information." United States v. Santiago-Ruiz, No. 17-60022-CRIM, 2017 WL 11454398, at *2 (S.D. Fla. Dec. 4, 2017) (quoting Conservancy of Sw. Fla. v. U.S. Fish and Wildlife Serv., No. 2:10-cv-106, 2010 WL 3603276 at *1 (M.D. Fla. Sept. 9, 2010)). Courts also grant amicus status where "participation as amicus curiae will alert the court to the legal contentions of concerned bystanders . . . ." Resort Timeshare, 764 F. Supp. at 1500–01 (citation omitted). Those considerations are met here. As experts in tax law and advocates for taxpayer interests and government accountability, amici provide useful information and legal arguments in this brief about the conflicts of interest among the named parties—conflicts that may prevent an adversarial presentation of the complaint's significant legal flaws. These arguments are of significant interest to taxpayers given the implications of this case for the rule of law and the public fisc. The brief by amici is timely, as this suit was filed only a week ago. CONCLUSION For the foregoing reasons, amici respectfully request that the Court grant their motion for leave to file their proposed amicus brief. LOCAL RULE 7.1(a)(3) CERTIFICATION Counsel for Amici Curiae Former Government Officials, Common Cause, and Project On Government Oversight have made reasonable efforts to confer with all parties for their position on this motion but have been unable to do so. Specifically, counsel for Amici Curiae emailed and left a phone message with counsel for Plaintiffs on Wednesday, February 4, 2026, around 3:45 p.m. ET. Plaintiffs' counsel has not yet responded to the request for Plaintiffs' position on this motion. Although the government has not yet entered an appearance in this matter, counsel for Amici Curiae emailed Matthew Feeley, Chief of the Civil Division for the U.S. Attorney's Office for the Southern District of Florida on Wednesday, February 4, 2026, around 3:45 p.m. ET. Counsel for Amici Curiae also spoke by phone with Angelo Frattarelli, a Department of Justice attorney who oversees civil matters relating to tax in the southern United States. Mr. Frattarelli stated that the government was not in a position to confer because no attorney had yet been assigned to this matter. Dated: February 5, 2026 Respectfully submitted, /s/ Gerald E. Greenberg GERALD E. GREENBERG · Florida Bar No. 440094 · [email protected] DANIEL R. WALSH · Florida Bar No. 0124282 · [email protected] GELBER SCHACHTER & GREENBERG, P.A. · One Southeast Third Avenue, Suite 2600 · Miami, Florida 33131 TSUKI HOSHIJIMA* ^ · [email protected] · Massachusetts Bar No. 693765 JYOTI JASRASARIA* · D.C. Bar No. 1671527 · [email protected] POOJA A. BOISTURE* ^ · New York Bar No. 5104559 · [email protected] AYESHA KHAN* · D.C. Bar No. 426836 · [email protected] ROBIN F. THURSTON* · D.C. Bar No. 1531399 · [email protected] SKYE L. PERRYMAN* · D.C. Bar No. 984573 · [email protected] DEMOCRACY FORWARD FOUNDATION · P.O. Box 34553 · Washington, D.C. 20043 *Pro hac vice forthcoming · ^ Not admitted to practice law in the District of Columbia; practicing under the supervision of Democracy Forward lawyers who are members of the District of Columbia Bar. Counsel for Amici Curiae Former Government Officials, Common Cause, and Project on Government Oversight CERTIFICATE OF SERVICE I HEREBY CERTIFY that on February 5, 2026, I electronically filed the foregoing with the Clerk of Court by using CM/ECF, which automatically serves all counsel of record for the parties who have appeared. Pursuant to Southern District of Florida Local Rule 5.2(a), I further certify that I served the foregoing on the following governmental entities who are defendants in this action or act as an entity which accepts service on behalf of the defendants in this action: (1) Internal Revenue Service, 1111 Constitution Ave, NW, Washington, DC 20224; (2) United States Office of the Attorney General, 950 Pennsylvania Avenue, NW, Washington, DC 20530; and (3) Southern District of Florida United States Attorney's Office, 99 N.E. 4th St., Miami, FL 33131. Service to these entities was made via mail pursuant to Federal Rule of Civil Procedure 5(b)(2)(C). /s/ Gerald E. Greenberg · GERALD E. GREENBERG · Florida Bar No. 440094 · [email protected]

COMPLAINT UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION PRESIDENT DONALD J. TRUMP, DONALD J. TRUMP JR., ERIC TRUMP, AND THE TRUMP ORGANIZATION, LLC. No. 1:26-cv-20609 JURY TRIAL DEMANDED Plaintiffs, v. INTERNAL REVENUE SERVICE AND U.S. DEPARTMENT OF THE TREASURY Defendants. 1. President Donald J. Trump is the Founder and former Chief Executive Officer of the Trump Organization. President Trump served as the 45th President of the United States, and is the 47th President of the United States. President Trump brings this suit in his personal capacity. 2. Donald J. Trump Jr. is an Executive Vice President at The Trump Organization, where he works to expand the company's real estate, retail, commercial, hotel, and golf interests. 3. Eric Trump is an Executive Vice President of the Trump Organization. He oversees all aspects of the management and operation of the global real estate business, including new project acquisition, development, and construction. 4. The Trump Organization is the preeminent developer of some of the most valuable and prized luxury real estate assets in the world, including five-star luxury hotels, championship golf courses, global realty services, residential & commercial buildings, property management, entertainment, dining, retail, and more. 5. The Trump Organization includes The Trump Organization, LLC, as well as 418 other entities that received notices from Defendant U.S. Department of the Treasury's Internal Revenue Service ("IRS") between December 2024 and May 2025 ("The Trump Organization"). 6. At all relevant times, President Donald J. Trump, Donald Trump Jr., Eric Trump, and The Trump Organization, LLC ("Plaintiffs") filed tax returns with the IRS, which contained confidential, personal financial information. 7. From May 2019 through at least September 2020, former IRS employee Charles "Chaz" Littlejohn, who was jointly employed by the IRS and/or one of its contractors, illegally obtained access to, and disclosed Plaintiffs' tax returns and return information to the New York Times, ProPublica, and other leftist media outlets. 8. Defendants had a duty to safeguard and protect Plaintiffs' confidential tax returns and related tax return information from such unauthorized inspection and public disclosure. See 26 U.S.C. § 6103, 5 U.S.C. § 552a. Accordingly, Defendants were obligated to have appropriate technical, employee screening, security, and monitoring systems to prevent Littlejohn's unlawful conduct. 9. Defendants failed to take such mandatory precautions. JURISDICTION AND VENUE 13. This Court has jurisdiction under 28 U.S.C. §§ 1331, 1340, 1346, 26 U.S.C. § 7431(a), and 5 U.S.C. § 552a(g)(1)(D). 14. Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b), because a substantial part of the events or omissions giving rise to the claim occurred in this judicial district. [FACTUAL ALLEGATIONS — Summary] I. Defendants Failed to Adequately Oversee Mr. Littlejohn 15–31. [Facts regarding Littlejohn's employment, IRS supervision and control, and legal basis for IRS liability.] II. Defendants Willfully Failed to Establish Appropriate Safeguards 32–47. [Facts regarding the IRS Inspector General's repeated warnings about security failures, Littlejohn's guilty plea, and how he exfiltrated the data.] III. Defendants Failed to Appropriately Screen Mr. Littlejohn 48–51. [Facts regarding failure to screen Littlejohn and failure to safeguard 6103-protected information.] IV. Defendants' Privacy Act Violations 52–86. [Facts regarding Littlejohn's disclosures to the New York Times and ProPublica, resulting published articles, and when Plaintiffs discovered the violations.] CLAIMS FOR RELIEF Count I — Violations of 26 U.S.C. § 6103 and 26 U.S.C. § 7431(a)(1) Count II — Violation of 5 U.S.C. § 552a(e)(10) PRAYER FOR RELIEF WHEREFORE, Plaintiffs President Donald Trump, Donald Trump Jr., Eric Trump, and the Trump Organization respectfully request that the Court enter judgment in their favor and against Defendants, declaring that Defendants willfully, knowingly, and/or by gross negligence unlawfully accessed and inspected Plaintiffs' confidential tax return information, and awarding statutory damages of $1,000 per unauthorized disclosure, actual damages, and punitive damages — in total, not less than $10 billion. JURY DEMAND Pursuant to Rule 38(a) of the Federal Rules of Civil Procedure, Plaintiffs demand a trial by jury of all claims asserted in this Complaint so triable. Filed: January 29, 2026

119TH CONGRESS · 2D SESSION · S. __ To provide for limitations on judgments, awards, and compromise settlements under section 1304 of title 31, United States Code. IN THE SENATE OF THE UNITED STATES Mr. SCHIFF (for himself, Mr. KELLY, and Ms. SLOTKIN) introduced the following bill. A BILL To provide for limitations on judgments, awards, and compromise settlements under section 1304 of title 31, United States Code. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. SHORT TITLE. This Act may be cited as the "Drain the Slush Fund Act". SEC. 2. JUDGMENTS, AWARDS, AND COMPROMISE SETTLEMENTS. (a) IN GENERAL.—Section 1304 of title 31, United States Code, is amended by adding at the end the following: "(e) No judgment, award, compromise settlement, interest, or costs shall be authorized for payments that arise out of a lawsuit or claim filed by the President or Vice President." (b) APPLICABILITY.—This section, and the amendments made by this section, shall apply to any pending case or any cause of action arising on or after January 20, 2025.

119TH CONGRESS · 2D SESSION · H.R. __ To prohibit the use of Federal funds for the payment of claims submitted to the Anti-Weaponization Fund. IN THE HOUSE OF REPRESENTATIVES Mr. FITZPATRICK (with Rep. SUOZZI) introduced the following bill. A BILL To prohibit the use of Federal funds for the payment of claims submitted to the Anti-Weaponization Fund. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. SHORT TITLE. This Act may be cited as the "Bipartisan Transparency for American Taxpayers Act". SEC. 2. PROHIBITION ON USE OF FEDERAL FUNDS FOR PAYMENT OF CLAIMS SUBMITTED TO ANTI-WEAPONIZATION FUND. Notwithstanding any other provision of law, no Federal funds, including funds appropriated under section 1304 of title 31, United States Code, may be used for the payment of any claim submitted to the Anti-Weaponization Fund, established by the Department of Justice on May 18, 2026.

119TH CONGRESS · 2D SESSION · H.R. __ To amend section 1304 of title 31, United States Code to restrict payments for compromise settlements or awards. IN THE HOUSE OF REPRESENTATIVES Mr. RASKIN introduced the following bill. A BILL To amend section 1304 of title 31, United States Code to restrict payments for compromise settlements or awards. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. SHORT TITLE. This Act may be cited as the "No Taxpayer-Funded Settlement Slush Funds Act of 2026". SEC. 2. RESTRICTION ON FEDERAL FUNDS IN CONNECTION WITH TRUMP, ET AL. V. IRS, ET AL. No Federal funds may be used to create or make payments to fund the compensation fund created by the settlement agreement entered into on May 18, 2026 in connection with the disposition of Trump, et al. v. IRS, et al., Civil Action No. 1:26-cv-20609-KMW. SEC. 3. RESTRICTION ON CERTAIN PAYMENTS FOR COMPROMISE SETTLEMENTS OR AWARDS. Section 1304 of title 31, United States Code, is amended by adding at the end the following: "(e) A compromise settlement or award may not be paid to— "(1) the President or Vice President; "(2) the parent, spouse, child, or spouse of a child of the President or Vice President; "(3) a presidentially-owned entity; "(4) any member of the cabinet; "(5) any individual employed by the Executive Office of the President paid at a rate equivalent to or exceeding the GS-15 level; "(6) a political appointee; and "(7) an individual who served in a position described under paragraph (4), (5), or (6) during the period for which the President who appointed such individual is in Office. "(f) A compromise settlement or award may not be paid with respect to a claim alleging harm resulting from an investigation, prosecution, or conviction for an offense related to— "(1) the January 6, 2021, attack on the United States Capitol; "(2) interference in the 2016 presidential election by a foreign government; or "(3) the same facts or circumstances as a civil action filed against the United States that was dismissed with prejudice. "(g)(1) Not later than 30 days after any payment of more than $100,000, the Secretary of the Treasury shall report to the Chair and Ranking Members of the Committees on the Judiciary disclosing: the name of the plaintiff or awardee; type of judgment; attorney names; agency names and approving officials; and a brief description of the facts. "(2) Prior notice is required to Judiciary Committees for any payment over $250,000, or any payment based on imminent litigation. A payment subject to notice may not be made for 120 days after notice is received. "(h) If a settlement is made in violation of subsection (e) or (f), the Attorney General may bring a civil action for injunctive relief and repayment. "(k) The Secretary of the Treasury may not establish a compensation fund, or approve a payment to such a fund, pursuant to a compromise settlement with the President or in violation of subsection (e) or (f). "(j) A settlement or award made on or after January 20, 2025 shall be subject to the requirements of subsections (e) through (h)."