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2022-2023 Donald Trump Confidential Documents Case - DoJ has asked Dearie for another day to secure a 3rd party vendor to create a portal to share info with Donald Trump

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Judge Raymond J. Dearie United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, NY 11202 Re: Donald J. Trump v. United States of America, Case No. 22-81294-CIV-CANNON - Government Motion to Modify and Adopt the Amended Case Management Plan (ECF 112) with Comments on the Amended Plan and Plaintiff's Objections Dear Judge Dearie: The government moves to modify the Amended Case Management Plan in order to contract directly with a document-review vendor. Besides that revision, the government moves to adopt the Amended Case Management Plan. See ECF 112, at 6-7. The government further comments on Executive-privilege review and Plaintiff's objections in the hope that the Special Master finds the comments helpful in administering the Amended Case Management Plan and considering Plaintiff's objections. Document-Review Vendor Plaintiff informed us this morning that none of the five document-review vendors proposed by the government before last Tuesday's preliminary conference were willing to be engaged by Plaintiff. To avoid further delay in the vendor's scanning and processing of the Seized Materials (defined to exclude "documents bearing classification markings"), the government issued a request for a task order this afternoon with a deadline of tomorrow (Wednesday, September 28, 2022) at noon. Based on its prior experience and discussions today with the vendors, the government is highly confident at least one vendor will respond and that it will be able to "agree upon and contract with a document review vendor that will host the Seized Materials in electronic form." ECF 112, at 3. Based on applicable procurement regulations, the government is not able to select and engage a vendor before tomorrow (Wednesday, September 28, 2022). Consistent with the Appointment Order (ECF 91 ¶ 14), the government expects Plaintiff to pay the vendor's invoices promptly when rendered. 1

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