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STATEMENT OF ISSUES 1. Whether the district court erred in exercising jurisdiction over Plaintiff's request for injunctive and other relief to constrain the government's review and use of all records seized pursuant to a court-authorized search in an ongoing criminal investigation. 2. Whether the district court erred by enjoining the government from reviewing and using records seized during that search for criminal investigative purposes, including records bearing classification markings, pending a months-long special- master review of Plaintiff's claims of executive and attorney-client privilege. 3. Whether the district court erred by ordering a special-master review of all seized records, including records bearing classification markings, where Plaintiff has no plausible claims of executive privilege and where the government implemented filter procedures to identify and protect attorney-client communications. 4

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Origin Entry: 2022-2023 Donald Trump Confidential Documents Case

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When you're getting indicted but your lawyer won't stop beatboxing

imgflip.com I MET DONALD TRUMP AND ALL I GOT WAS A SECRET DOCUMENT

JUSTICE F--- around. Find out.

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SCOTUS refuses to hear Trump appeal over Mar-a-Lago documents. No noted dissents.

(ORDER LIST: 598 U.S.) 22A283 THURSDAY, OCTOBER 13, 2022 ORDER IN PENDING CASE TRUMP, DONALD J. V. UNITED STATES The application to vacate the stay entered by the United States Court of Appeals for the Eleventh Circuit on September 21, 2022, presented to Justice Thomas and by him referred to the Court is denied.

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Select all images with top secret documents

Select all images with Top Secret Documents 36 SECRETISCI SECRET SCI 2 TOP SECRETINGA RETO 2A

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JUST IN: Appeals court grants DOJ motion to expedite appeal of Judge Cannon’s order appointing special master to oversee seized Mar-a-Lago docs.

IN THE UNITED STATES COURT OF APPEALS FOR THE ELEVENTH CIRCUIT DONALD J. TRUMP, UNITED STATES OF AMERICA, ORDER: No. 22-13005-DD versus Plaintiff - Appellee, Defendant Appellant. On Appeal from the United States District Court for the Southern District of Florida Appellant's "Motion to Expedite Appeal" is granted. The Court directs the Clerk to expedite the appeal for merits disposition purposes. Having consulted with the Chief Judge, the appeal will be assigned to a special merits panel from the classified appeals log randomly selected by the Clerk. That panel will decide when and how to hear oral argument. The Court sets the following expedited briefing schedule, with no extensions allowed: Appellant's initial brief is due on or before October 14, 2022. Appellee's response brief is due on November 10, 2022. Appellant's reply brief, if any, is due on November 17, 2022. /s/ Adalberto Jordan UNITED STATES CIRCUIT JUDGE

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Things Trump has to pay for

For one, a special master will cost a lot of money. Judge Cannon rejected Mr. Trump's proposal that taxpayers should foot half the bill of the review, instead saying he would be solely responsible. That includes the full cost of a vendor who will scan all the materials, as well as support staff for Judge Dearie, like an assistant who bills $500 an hour. Mr. Trump will also have to pay his own lawyers' fees as they filter thousands of pages of records and then litigate disputes about which ones can be withheld as privileged.

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Updated Inventory

Item #2 - Box/Container from Office 99 10/2018 Magazines/Newspapers/Press Articles and Other Printed Media dated between 01/2017- 2 US Government Documents with CONFIDENTIAL Classification Markings 15 US Government Documents with SECRET Classification Markings 7 US Government Documents with TOP SECRET Classification Markings 74 US Government Documents/Photographs without Classification Markings 43 Empty Folders with "CLASSIFIED" Banners 28 Empty Folders Labeled "Return to Staff Secretary/Miliary Aide"

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DoJ has asked Dearie for another day to secure a 3rd party vendor to create a portal to share info with Donald Trump

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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Special Master tells Trump's lawyers to say once and for all whether they really think the FBI planted evidence

No later than September 30, 2022, Plaintiff shall submit a declaration or affidavit that includes each of the following factual matters: a. A list of any specific items set forth in the Detailed Property Inventory that Plaintiff asserts were not seized from the Premises on August 8, 2022.

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JUST IN: Judge Cannon has responded to the 11th Circuit Court of Appeals stay decision by striking aspects of her order appointing a special master.

DONALD J. TRUMP, V. Plaintiff, UNITED STATES OF AMERICA, Defendant. ORDER FOLLOWING PARTIAL STAY THIS CAUSE comes before the Court following the Eleventh Circuit's Order granting the Government's Motion for Partial Stay Pending Appeal. See Trump v. United States, No. 22-13005 (11th Cir. Sept. 21, 2022). The Eleventh Circuit's Order stays the Court's Order [ECF No. 64] to the extent it enjoins the Government's use of the approximately one-hundred documents bearing classification markings and requires the Government to submit those documents to the Special Master for review. In accordance with the Eleventh Circuit's Order, it is hereby ORDERED AND ADJUDGED as follows: 1. The term "seized material" in the Court's Order Appointing Special Master [ECF No. 91] is modified to include all materials seized on August 8, 2022, except the approximately one-hundred documents bearing classification markings [ECF No. 91 ¶2]. 2. Paragraph 5(b)(i)(bb) of the Order Appointing Special Master is hereby STRICKEN [ECF No. 9115]. 3. Paragraph 6 of the Order Appointing Special Master is hereby STRICKEN [ECF No. 91 ¶6].

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Dark Brandon reclassifying with his mind

S. 1 RE-CLASSIFIED THE DOCUMENTS JUST BY THINKING ABOUT IT

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Red Herring

Plaintiff suggests that he may have declassified these docu- ments when he was President. But the record contains no evidence that any of these records were declassified. And before the special master, Plaintiff resisted providing any evidence that he had declas- sified any of these documents. See Doc. No. 97 at 2–3., Sept. 19, 2022, letter from James M. Trusty, et al., to Special Master Ray- mond J. Dearie, at 2-3. In any event, at least for these purposes, the declassification argument is a red herring because declassifying an official document would not change its content or render it per- sonal. So even if we assumed that Plaintiff did declassify some or all of the documents, that would not explain why he has a personal interest in them.

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Ouch. 11th circuit destroys Trump’s entire argument in one paragraph.

Plaintiff has not even attempted to show that he has a need to know the information contained in the classified documents. Nor has he established that the current administration has waived that requirement for these documents. And even if he had, that, in USCA11 Case: 22-13005 Date Filed: 09/21/2022 Page: 19 of 29 22-13005 Opinion of the Court and of itself, would not explain why Plaintiff has an individual in- terest in the classified documents. 19 Plaintiff suggests that he may have declassified these docu-

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BREAKING: Appeals Court panel grants DOJ request for a stay of parts of Judge Cannon’s ruling

Opinion of the Court Before ROSENBAUM, GRANT, and BRASHER, Circuit Judges. PER CURIAM: 2 22-13005 Following the execution of a search warrant at the residence of Plaintiff-Appellee, former President Donald J. Trump, Plaintiff moved for the appointment of a special master to review the doc- uments that Defendant-Appellant United States of America seized. The district court granted that motion in substantial part. Now, the United States moves for a partial stay of the district court's or- der as it relates to the roughly one-hundred documents bearing classification markings. We decide only the narrow question pre- sented: whether the United States has established that it is entitled to a stay of the district court's order, to the extent that it (1) requires the government to submit for the special master's review the doc- uments with classification markings and (2) enjoins the United States from using that subset of documents in a criminal investiga- tion. We conclude that it has. We stress the limited nature of our review: this matter comes to us on a motion for a partial stay pending appeal. We can- not (and do not) decide the merits of this case. We decide only the traditional equitable considerations, including whether the United States has shown a substantial likelihood of prevailing on the mer- its, the harm each party might suffer from a stay, and where the public interest lies. For the reasons we explain below, we grant the United States's motion for a partial stay pending appeal.

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2022-2023 Donald Trump Confidential Documents Case - Statement of Issues

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STATEMENT OF ISSUES 1. Whether the district court erred in exercising jurisdiction over Plaintiff's request for injunctive and other relief to constrain the government's review and use of all records seized pursuant to a court-authorized search in an ongoing criminal investigation. 2. Whether the district court erred by enjoining the government from reviewing and using records seized during that search for criminal investigative purposes, including records bearing classification markings, pending a months-long special- master review of Plaintiff's claims of executive and attorney-client privilege. 3. Whether the district court erred by ordering a special-master review of all seized records, including records bearing classification markings, where Plaintiff has no plausible claims of executive privilege and where the government implemented filter procedures to identify and protect attorney-client communications. 4

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