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Ex. 3

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P. 38

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P. 38

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USCA Case #21-5254
Document #1922646
Filed: 11/16/2021
Page 157 of 287

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Filed: 11/16/2021
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USCA Case #21-5254
Document #1922646
Filed: 11/16/2021
Page 160 of 287

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Ex. 12

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Ex. 13

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Ex. 14

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From:John Hamilton <john.hamilton@nara.gov>
315
Sent time:

02/09/2022 02:25:05 PM

To:

Ferriero, David <david.ferriero@nara.gov>; Wall, Debra <debra.wall@nara.gov>; Bosanko, William <william.bosanko@nara.gov>; Stern, GaryM<garym.stern@nara.gov>; John Valceanu <john.valceanu@nara.gov>; Stanwich, Maria <maria.stanwich@nara.gov>; NARA Executive Secretariat<ExecSec@nara.gov>; Donius, Susan <susan.donius@nara.gov>; Laster, John <john.laster@nara.gov>

BCc:(b) (6)

Subject:

Fwd: Letter for The Honorable David S. Ferriero, Archivist of the United States, National Archives and Records Administration@nara.gov

Attachments: 2022-02-09.CBM to Ferriero-NARA re Trump Mar-a-Lago.pdf

Here is the letter we knew was coming.....I have acknowledged our receipt of this letter.
John---------- Forwarded message --------From: (b) (6)<(b) (6)>Date: Wed, Feb 9, 2022 at 2:17 PM
Subject: Letter for The Honorable David S. Ferriero, Archivist of the United States, National Archives and Records
Administration
To: john.hamilton@nara.gov <john.hamilton@nara.gov>, garym.stern@nara.gov <garym.stern@nara.gov>,
congress.affairs@nara.gov <congress.affairs@nara.gov>
Cc: (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>Hello—

Please see the attached letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, for The Honorable
David S. Ferriero, Archivist of the United States, National Archives and Records Administration.

Please acknowledge receipt of the letter. Thank you.

Sincerely,(b) (6)
Staff Assistant | Committee on Oversight & Reform
Chairwoman Carolyn B. Maloney(b) (6)-John O. Hamilton
Director of Congressional Affairs

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National
Archives and Records Administration
315
700 Pennsylvania Avenue, NW
Washington, DC 20408-0001
PH: 202-357-6832
Cell: (b) (6)Fax: 202-3575959

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February 9, 2022
The Honorable David S. Ferriero
Archivist of the United States
National Archives and Records Administration
8601 Adelphi Road
College Park, MD 20740-6001
Dear Mr. Ferriero:
The Committee is seeking information about the 15 boxes of presidential records that the
National Archives and Records Administration (NARA) recently recovered from former
President Trump’s Mar-a-Lago residence. I am deeply concerned that these records were notprovided to NARA promptly at the end of the Trump Administration and that they appear tohave been removed from the White House in violation of the Presidential Records Act (PRA). I
am also concerned by recent reports that while in office, President Trump repeatedly attempted
to destroy presidential records, which could constitute additional serious violations of the PRA.
The PRA preserves the records made by a sitting president, while giving legal ownershipof those records to the American people.1 Congress enacted the PRA in response to President
Nixon’s attempts to destroy presidential records during the Watergate scandal.
President Trump is required not only to preserve presidential records, but to turn themover to the National Archives at the end of his presidential term. The PRA specifically states:
Upon the conclusion of a President’s term of office, or if a President serves consecutive
terms upon the conclusion of the last term, the Archivist of the United States shallassume responsibility for the custody, control, and preservation of, and access to,
the Presidential records of that President. 2
On February 7, 2022, the Washington Post reported that former President Trump
improperly removed 15 boxes of records from the White House and transported them to his Mara-Lago residence. These boxes reportedly contained correspondence and letters from world
leaders, including correspondence with North Korean leader Kim Jong-un, and a letter President1

See 44 U.S.C. §§ 2201–2209.

2

44 U.S.C. § 2203(g)(1) (emphasis added).

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The Honorable David S. Ferriero
Page 2
Obama left for his successor.3 The records recovered from Mar-a-Lago also reportedly include
several newspaper clippings. A previous Committee investigation revealed that President Trump
wrote notes on press clippings, which could mean that even those clippings were likely
presidential records.4
On February 5, 2022, it was reported that while in office, former President Trump “toreup briefings and schedules, articles and letters, memos both sensitive and mundane.”5
Removing or concealing government records is a criminal offense punishable by up to
three years in prison. Former National Security Advisor Sandy Berger, for example, wasprosecuted for taking classified documents from NARA. 6 Former President Trump and his
senior advisors must also be held accountable for any violations of the law. Republicans inCongress obsessively investigated former Secretary of State Hillary Clinton for her use of a
private email server for official communications. Former President Trump’s conduct, incontrast, involves a former president potentially violating a criminal law by intentionally
removing records, including communications with a foreign leader, from the White House andreportedly attempting to destroy records by tearing them up.
In order for the Committee to examine the extent and impact of former President Trump’s
violations of the PRA, please provide responses to the following requests by February 18, 2022:
1.

Did NARA ask the representatives of former President Trump about missing
records prior to the 15 boxes being identified? If so, what information wasprovided in response?

2.

Has NARA conducted an inventory of the contents of the boxes recovered from
Mar-a-Lago?

3.

Please provide a detailed description of the contents of the recovered boxes,
including any inventory prepared by NARA of the contents of the boxes. If an
inventory has not yet been completed, please provide an estimate of when such an
inventory will be completed.

National Archives Had to Retrieve Trump White House Records from Mar-a-Lago, Washington Post
(Feb. 7, 2022) (online at www.washingtonpost.com/politics/2022/02/07/trump-records-mar-a-lago/).
3

Committee on Oversight and Reform, Press Release: Committee Chairs Release New Documents
Showing Mar-a-Lago Trio Violated Transparency Law and Improperly Influenced Veterans Policies Under
President Trump (Sept. 27, 2021) (online at https://oversight house.gov/news/press-releases/committee-chairsrelease-new-documents-showing-mar-a-lago-trio-violated).
4

5“He Never Stopped Ripping Things Up”: Inside Trump’s Relentless Document Destruction Habits,
Washington Post (Feb. 5, 2022) (online at www.washingtonpost.com/politics/2022/02/05/trump-rippingdocuments).
See e.g., National Archives and Records Administration, Notable Thefts from the National Archives(online at www.archives.gov/research/recover/notable-thefts html) (accessed Feb. 8, 2022).
6

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The Honorable David S. Ferriero
Page 2
4.

Are the contents of the boxes of records recovered by NARA undergoing a review
to determine if they contain classified information? If so, who is conducting that
review and has any classified information been found?

5.

Is NARA aware of any additional presidential records from the Trump
Administration that may be missing or not yet in NARA’s possession?

6.

What efforts has NARA taken, and is NARA taking, to ensure that any additional
records that have not been turned over to NARA are not lost or destroyed?

7.

Has the Archivist notified the Attorney General that former President Trump
removed presidential records from the White House? If not, why not?

8.

Is NARA aware of presidential records that President Trump destroyed or
attempted to destroy without the approval of NARA? If so, please provide a
detailed description of such records, the actions taken by President Trump to
destroy or attempt to destroy them, and any actions NARA has taken to recover orpreserve these documents.

The Committee on Oversight and Reform is the principal oversight committee of theHouse of Representatives and has broad authority to investigate “any matter” at “any time” underHouse Rule X. In addition, House Rule X states that the Committee on Oversight and Reform
has jurisdiction to “study on a continuing basis the operation of Government activities at alllevels, including the Executive Office of the President.”
An attachment to this letter provides additional instructions for responding to theCommittee’s request. If you have any questions regarding this request, please contact theOversight Committee staff at (202) 225-5051.
Thank you for your prompt attention to this matter.
Sincerely,__________________________
Carolyn B. Maloney
Chairwoman
Enclosurecc:

The Honorable James Comer, Ranking Member

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Responding to Oversight Committee Document Requests
1.

In complying with this request, produce all responsive documents that are in yourpossession, custody, or control, whether held by you or your past or present agents,
employees, and representatives acting on your behalf. Produce all documents that you
have a legal right to obtain, that you have a right to copy, or to which you have access, aswell as documents that you have placed in the temporary possession, custody, or control
of any third party.

2.

Requested documents, and all documents reasonably related to the requested documents,
should not be destroyed, altered, removed, transferred, or otherwise made inaccessible to
the Committee.

3.

In the event that any entity, organization, or individual denoted in this request is or has
been known by any name other than that herein denoted, the request shall be read also toinclude that alternative identification.

4.

The Committee’s preference is to receive documents in electronic form (i.e., CD,memory stick, thumb drive, or secure file transfer) in lieu of paper productions.

5.

Documents produced in electronic format should be organized, identified, and indexed
electronically.

6.

Electronic document productions should be prepared according to the following
standards:a.

The production should consist of single page Tagged Image File (“TIF”), files
accompanied by a Concordance-format load file, an Opticon reference file, and afile defining the fields and character lengths of the load file.

b.

Document numbers in the load file should match document Bates numbers and
TIF file names.

c.

If the production is completed through a series of multiple partial productions,field names and file order in all load files should match.

d.

All electronic documents produced to the Committee should include the following
fields of metadata specific to each document, and no modifications should bemade to the original metadata:
BEGDOC, ENDDOC, TEXT, BEGATTACH, ENDATTACH, PAGECOUNT,CUSTODIAN, RECORDTYPE, DATE, TIME, SENTDATE, SENTTIME,
BEGINDATE, BEGINTIME, ENDDATE, ENDTIME, AUTHOR, FROM, CC,
TO, BCC, SUBJECT, TITLE, FILENAME, FILEEXT, FILESIZE,DATECREATED, TIMECREATED, DATELASTMOD, TIMELASTMOD,

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INTMSGID, INTMSGHEADER, NATIVELINK, INTFILPATH, EXCEPTION,
BEGATTACH.
7.

Documents produced to the Committee should include an index describing the contentsof the production. To the extent more than one CD, hard drive, memory stick, thumbdrive, zip file, box, or folder is produced, each should contain an index describing its
contents.

8.

Documents produced in response to this request shall be produced together with copies offile labels, dividers, or identifying markers with which they were associated when therequest was served.

9.

When you produce documents, you should identify the paragraph(s) or request(s) in theCommittee’s letter to which the documents respond.

10.

The fact that any other person or entity also possesses non-identical or identical copies ofthe same documents shall not be a basis to withhold any information.

11.

The pendency of or potential for litigation shall not be a basis to withhold any
information.

12.

In accordance with 5 U.S.C.§ 552(d), the Freedom of Information Act (FOIA) and any
statutory exemptions to FOIA shall not be a basis for withholding any information.

13.

Pursuant to 5 U.S.C. § 552a(b)(9), the Privacy Act shall not be a basis for withholding
information.

14.

If compliance with the request cannot be made in full by the specified return date,compliance shall be made to the extent possible by that date. An explanation of why fullcompliance is not possible shall be provided along with any partial production.

15.

In the event that a document is withheld on the basis of privilege, provide a privilege log
containing the following information concerning any such document: (a) every privilege
asserted; (b) the type of document; (c) the general subject matter; (d) the date, author,
addressee, and any other recipient(s); (e) the relationship of the author and addressee toeach other; and (f) the basis for the privilege(s) asserted.

16.

If any document responsive to this request was, but no longer is, in your possession,custody, or control, identify the document (by date, author, subject, and recipients), andexplain the circumstances under which the document ceased to be in your possession,custody, or control.

17.

If a date or other descriptive detail set forth in this request referring to a document is
inaccurate, but the actual date or other descriptive detail is known to you or is otherwise
apparent from the context of the request, produce all documents that would be responsive
as if the date or other descriptive detail were correct.

2

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18.

This request is continuing in nature and applies to any newly-discovered information.
Any record, document, compilation of data, or information not produced because it has
not been located or discovered by the return date shall be produced immediately upon
subsequent location or discovery.

19.

All documents shall be Bates-stamped sequentially and produced sequentially.

20.

Two sets of each production shall be delivered, one set to the Majority Staff and one set
to the Minority Staff. When documents are produced to the Committee, production setsshall be delivered to the Majority Staff in Room 2157 of the Rayburn House Office
Building and the Minority Staff in Room 2105 of the Rayburn House Office Building.

21.

Upon completion of the production, submit a written certification, signed by you or yourcounsel, stating that: (1) a diligent search has been completed of all documents in yourpossession, custody, or control that reasonably could contain responsive documents; and(2) all documents located during the search that are responsive have been produced to theCommittee.
Definitions

1.

The term “document” means any written, recorded, or graphic matter of any naturewhatsoever, regardless of how recorded, and whether original or copy, including, but notlimited to, the following: memoranda, reports, expense reports, books, manuals,
instructions, financial reports, data, working papers, records, notes, letters, notices,confirmations, telegrams, receipts, appraisals, pamphlets, magazines, newspapers,
prospectuses, communications, electronic mail (email), contracts, cables, notations of any
type of conversation, telephone call, meeting or other inter-office or intra-officecommunication, bulletins, printed matter, computer printouts, teletypes, invoices,transcripts, diaries, analyses, returns, summaries, minutes, bills, accounts, estimates,
projections, comparisons, messages, correspondence, press releases, circulars, financial
statements, reviews, opinions, offers, studies and investigations, questionnaires andsurveys, and work sheets (and all drafts, preliminary versions, alterations, modifications,revisions, changes, and amendments of any of the foregoing, as well as any attachments
or appendices thereto), and graphic or oral records or representations of any kind(including without limitation, photographs, charts, graphs, microfiche, microfilm,
videotape, recordings and motion pictures), and electronic, mechanical, and electricrecords or representations of any kind (including, without limitation, tapes, cassettes,
disks, and recordings) and other written, printed, typed, or other graphic or recorded
matter of any kind or nature, however produced or reproduced, and whether preserved inwriting, film, tape, disk, videotape, or otherwise. A document bearing any notation not apart of the original text is to be considered a separate document. A draft or non-identical
copy is a separate document within the meaning of this term.

2.

The term “communication” means each manner or means of disclosure or exchange of
information, regardless of means utilized, whether oral, electronic, by document orotherwise, and whether in a meeting, by telephone, facsimile, mail, releases, electronic3

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message including email (desktop or mobile device), text message, instant message,
MMS or SMS message, message application, or otherwise.
3.

The terms “and” and “or” shall be construed broadly and either conjunctively or
disjunctively to bring within the scope of this request any information that mightotherwise be construed to be outside its scope. The singular includes plural number, andvice versa. The masculine includes the feminine and neutral genders.

4.

The term “including” shall be construed broadly to mean “including, but not limited to.”5.

The term “Company” means the named legal entity as well as any units, firms,
partnerships, associations, corporations, limited liability companies, trusts, subsidiaries,
affiliates, divisions, departments, branches, joint ventures, proprietorships, syndicates, orother legal, business or government entities over which the named legal entity exercises
control or in which the named entity has any ownership whatsoever.

6.

The term “identify,” when used in a question about individuals, means to provide thefollowing information: (a) the individual’s complete name and title; (b) the
individual’s business or personal address and phone number; and (c) any and all
known aliases.

7.

The term “related to” or “referring or relating to,” with respect to any given subject,means anything that constitutes, contains, embodies, reflects, identifies, states, refers to,deals with, or is pertinent to that subject in any manner whatsoever.

8.

The term “employee” means any past or present agent, borrowed employee, casual
employee, consultant, contractor, de facto employee, detailee, fellow, independent
contractor, intern, joint adventurer, loaned employee, officer, part-time employee,permanent employee, provisional employee, special government employee,
subcontractor, or any other type of service provider.

9.

The term “individual” means all natural persons and all persons or entities acting on
their behalf.

4

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Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 71 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 72 of315

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Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 74 of315

Ex. 16Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 75 of
From:
William Bosanko <william.bosanko@nara.gov>
315
Sent time: 02/09/2022 03:03:55 PM
To:

John Hamilton <john.hamilton@nara.gov>

Cc:

Ferriero, David <david.ferriero@nara.gov>; Wall, Debra <debra.wall@nara.gov>; Stern, GaryM <garym.stern@nara.gov>; John Valceanu<john.valceanu@nara.gov>; Stanwich, Maria <maria.stanwich@nara.gov>; NARA Executive Secretariat <ExecSec@nara.gov>; Donius, Susan<susan.donius@nara.gov>; Laster, John <john.laster@nara.gov>

BCc:(b) (6)

Subject:

Re: Letter for The Honorable David S. Ferriero, Archivist of the United States, National Archives and Records Administration@nara.gov

Thanks John. Gary and I have alerted NARA OIG, ODNI OIG, and DOJ.
Jay
On Wed, Feb 9, 2022 at 2:25 PM John Hamilton <john.hamilton@nara.gov> wrote:
Here is the letter we knew was coming.....I have acknowledged our receipt of this letter.
John---------- Forwarded message --------From: (b) (6)<(b) (6)>Date: Wed, Feb 9, 2022 at 2:17 PM
Subject: Letter for The Honorable David S. Ferriero, Archivist of the United States, National Archives and Records
Administration
To: john.hamilton@nara.gov <john.hamilton@nara.gov>, garym.stern@nara.gov <garym.stern@nara.gov>,
congress.affairs@nara.gov <congress.affairs@nara.gov>
Cc: (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>, (b) (6)<(b) (6)>Hello—

Please see the attached letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, for The Honorable
David S. Ferriero, Archivist of the United States, National Archives and Records Administration.

Please acknowledge receipt of the letter. Thank you.

Sincerely,(b) (6)
Staff Assistant | Committee on Oversight & Reform
Chairwoman Carolyn B. Maloney(b) (6)

15B000125

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 76 of
315-John O. Hamilton
Director of Congressional Affairs
National Archives and Records Administration
700 Pennsylvania Avenue, NW
Washington, DC 20408-0001
PH: 202-357-6832
Cell: (b) (6)Fax: 202-3575959

15B000126

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Ex. 17

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Ex. 22

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315
MONDAY, FEB 28•e•e

Oliver Potts Feb 28, 2022, 3:19 PM

hi Jay...any headway on getting WH to consider fate of the books with us?
William Bosanko Feb 28, 2022, 3:20 PM.••

None - the 15 boxes from mar-a-Iago have consummed all of our discussions
DO you have bullets or something I can aib from to send an email
Oliver Potts Feb 28, 2022, 3:21 PM
definitely...will send
William Bosanko Feb 28, 2022, 3:21 PM
Thxl That will help

15B001256

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Ex. 23

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Ex. 24

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315

May 10, 2022
Evan Corcoran
Silverman Thompson
400 East Pratt Street
Suite 900
Baltimore, MD 21202
By Email
Dear Mr. Corcoran:
I write in response to your letters of April 29, 2022, and May 1, 2022, requesting that the
National Archives and Records Administration (NARA) further delay the disclosure to theFederal Bureau of Investigation (FBI) of the records that were the subject of our April 12, 2022
notification to an authorized representative of former President Trump.
As you are no doubt aware, NARA had ongoing communications with the former President’s
representatives throughout 2021 about what appeared to be missing Presidential records, which
resulted in the transfer of 15 boxes of records to NARA in January 2022. In its initial review ofmaterials within those boxes, NARA identified items marked as classified national security
information, up to the level of Top Secret and including Sensitive Compartmented Informationand Special Access Program materials. NARA informed the Department of Justice about that
discovery, which prompted the Department to ask the President to request that NARA provide
the FBI with access to the boxes at issue so that the FBI and others in the Intelligence
Community could examine them. On April 11, 2022, the White House Counsel’s
Office—affirming a request from the Department of Justice supported by an FBI letterhead
memorandum—formally transmitted a request that NARA provide the FBI access to the 15
boxes for its review within seven days, with the possibility that the FBI might request copies of
specific documents following its review of the boxes.
Although the Presidential Records Act (PRA) generally restricts access to Presidential records in
NARA’s custody for several years after the conclusion of a President’s tenure in office, thestatute further provides that, “subject to any rights, defenses, or privileges which the UnitedStates or any agency or person may invoke,” such records “shall be made available . . . to anincumbent President if such records contain information that is needed for the conduct of current
business of the incumbent President’s office and that is not otherwise available.” 44 U.S.C. §Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 108 of
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2205(2)(B). Those conditions are satisfied here. As the Department of Justice’s National Security
Division explained to you on April 29, 2022:
There are important national security interests in the FBI and others in the Intelligence
Community getting access to these materials. According to NARA, among the materials
in the boxes are over 100 documents with classification markings, comprising more than
700 pages. Some include the highest levels of classification, including Special Access
Program (SAP) materials. Access to the materials is not only necessary for purposes ofour ongoing criminal investigation, but the Executive Branch must also conduct anassessment of the potential damage resulting from the apparent manner in which thesematerials were stored and transported and take any necessary remedial steps.
Accordingly, we are seeking immediate access to these materials so as to facilitate thenecessary assessments that need to be conducted within the Executive Branch.
We advised you in writing on April 12 that, “in light of the urgency of this request,” we planned
to “provid[e] access to the FBI next week,” i.e., the week of April 18. See Exec. Order No.
13,489, § 2(b), 74 Fed. Reg. 4,669 (Jan. 21, 2009) (providing a 30-day default before disclosure
but authorizing the Archivist to specify “a shorter period of time” if “required under thecircumstances”); accord 36 C.F.R. § 1270.44(g) (“The Archivist may adjust any time period ordeadline under this subpart, as appropriate, to accommodate records requested under thissection.”). In response to a request from another representative of the former President, theWhite House Counsel’s Office acquiesced in an extension of the production date to April 29, andso advised NARA. In accord with that agreement, we had not yet provided the FBI with accessto the records when we received your letter on April 29, and we have continued to refrain fromproviding such access to date.
It has now been four weeks since we first informed you of our intent to provide the FBI access tothe boxes so that it and others in the Intelligence Community can conduct their reviews.
Notwithstanding the urgency conveyed by the Department of Justice and the reasonable
extension afforded to the former President, your April 29 letter asks for additional time for you toreview the materials in the boxes “in order to ascertain whether any specific document is subject
to privilege,” and then to consult with the former President “so that he may personally make any
decision to assert a claim of constitutionally based privilege.” Your April 29 letter further statesthat in the event we do not afford you further time to review the records before NARA discloses
them in response to the request, we should consider your letter to be “a protective assertion of
executive privilege made by counsel for the former President.”
The Counsel to the President has informed me that, in light of the particular circumstancespresented here, President Biden defers to my determination, in consultation with the AssistantAttorney General for the Office of Legal Counsel, regarding whether or not I should uphold theformer President’s purported “protective assertion of executive privilege.” See 36 C.F.R. §1270.44(f)(3). Accordingly, I have consulted with the Assistant Attorney General for the Officeof Legal Counsel to inform my “determination as to whether to honor the former President’s
claim of privilege or instead to disclose the Presidential records notwithstanding the claim ofprivilege.” Exec. Order No. 13,489, § 4(a).

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The Assistant Attorney General has advised me that there is no precedent for an assertion of
executive privilege by a former President against an incumbent President to prevent the latterfrom obtaining from NARA Presidential records belonging to the Federal Government where“such records contain information that is needed for the conduct of current business of theincumbent President’s office and that is not otherwise available.” 44 U.S.C. § 2205(2)(B).
To the contrary, the Supreme Court’s decision in Nixon v. Administrator of General Services, 433
U.S. 425 (1977), strongly suggests that a former President may not successfully assert executive
privilege “against the very Executive Branch in whose name the privilege is invoked.” Id. at
447-48. In Nixon v. GSA, the Court rejected former President Nixon’s argument that a statuterequiring that Presidential records from his term in office be maintained in the custody of, andscreened by, NARA’s predecessor agency—a “very limited intrusion by personnel in the
Executive Branch sensitive to executive concerns”—would “impermissibly interfere with candid
communication of views by Presidential advisers.” Id. at 451; see also id. at 455 (rejecting theclaim). The Court specifically noted that an “incumbent President should not be dependent on
happenstance or the whim of a prior President when he seeks access to records of past decisions
that define or channel current governmental obligations.” Id. at 452; see also id. at 441-46(emphasizing, in the course of rejecting a separation-of-powers challenge to a provision of afederal statute governing the disposition of former President Nixon’s tape recordings, papers, andother historical materials “within the Executive Branch,” where the “employees of that branch[would] have access to the materials only ‘for lawful Government use,’” that “[t]he Executive
Branch remains in full control of the Presidential materials, and the Act facially is designed toensure that the materials can be released only when release is not barred by some applicableprivilege inherent in that branch”; and concluding that “nothing contained in the Act renders it
unduly disruptive of the Executive Branch”).
It is not necessary that I decide whether there might be any circumstances in which a former
President could successfully assert a claim of executive privilege to prevent an Executive Branchagency from having access to Presidential records for the performance of valid executivefunctions. The question in this case is not a close one. The Executive Branch here is seeking
access to records belonging to, and in the custody of, the Federal Government itself, not only inorder to investigate whether those records were handled in an unlawful manner but also, as the
National Security Division explained, to “conduct an assessment of the potential damage
resulting from the apparent manner in which these materials were stored and transported and takeany necessary remedial steps.” These reviews will be conducted by current government
personnel who, like the archival officials in Nixon v. GSA, are “sensitive to executive concerns.”
Id. at 451. And on the other side of the balance, there is no reason to believe such reviews could“adversely affect the ability of future Presidents to obtain the candid advice necessary for
effective decisionmaking.” Id. at 450. To the contrary: Ensuring that classified information isappropriately protected, and taking any necessary remedial action if it was not, are steps essential
to preserving the ability of future Presidents to “receive the full and frank submissions of facts
and opinions upon which effective discharge of [their] duties depends.” Id. at 449.
Because an assertion of executive privilege against the incumbent President under thesecircumstances would not be viable, it follows that there is no basis for the former President tomake a “protective assertion of executive privilege,” which the Assistant Attorney GeneralCase 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 110 of315

informs me has never been made outside the context of a congressional demand for informationfrom the Executive Branch. Even assuming for the sake of argument that a former President may
under some circumstances make such a “protective assertion of executive privilege” to preclude
the Archivist from complying with a disclosure otherwise prescribed by 44 U.S.C. § 2205(2),there is no predicate for such a “protective” assertion here, where there is no realistic basis thatthe requested delay would result in a viable assertion of executive privilege against theincumbent President that would prevent disclosure of records for the purposes of the reviews
described above. Accordingly, the only end that would be served by upholding the “protective”
assertion here would be to delay those very important reviews.
I have therefore decided not to honor the former President’s “protective” claim of privilege. See
Exec. Order No. 13,489, § 4(a); see also 36 C.F.R. 1270.44(f)(3) (providing that unless theincumbent President “uphold[s]” the claim asserted by the former President, “the Archivist
discloses the Presidential record”). For the same reasons, I have concluded that there is no reason
to grant your request for a further delay before the FBI and others in the Intelligence Community
begin their reviews. Accordingly, NARA will provide the FBI access to the records in question ,as requested by the incumbent President, beginning as early as Thursday, May 12, 2022.
Please note that, in accordance with the PRA, 44 U.S.C. § 2205(3), the former President’s
designated representatives can review the records, subject to obtaining the appropriate level of
security clearance. Please contact my General Counsel, Gary M. Stern, if you would like todiscuss the details of such a review, such as you proposed in your letter of May 5, 2022,
particularly with respect to any unclassified materials.
Sincerely,

DEBRA STEIDEL WALL
Acting Archivist of the United States

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TODD BLANCHE
Todd.Blanche@blanchelaw.com(212) 716-1250

October 9, 2023
Via EmailJay Bratt
Julie EdelsteinDavid Harbach
Senior Assistant Special Counsels
950 Pennsylvania Avenue NW
Room B-206
Washington, D.C. 20530
Re:

United States v. Donald J. Trump, No. 23 Cr. 80101 (AMC)

Dear Mr. Bratt, Ms. Edelstein, and Mr. Harbach:
We write on behalf of President Trump, pursuant to Rule 16(a)(1)(E), Brady, and Giglio,
to request the documents and information set forth below. In light of the current motions schedule,
we respectfully request a response no later than October 16, 2023.
I.

Background

Each of the Requests set forth below calls for production of documents irrespective of theirclassification level. As used herein, the term “documents” includes (i) all communications,
including memoranda, reports, letters, notes, emails, text messages, and other electronic
communications; (ii) hard copies and electronically stored information, whether written, printed,
or typed; and (iii) all drafts and copies.
The Requests call for specified documents in the possession of the prosecution team. For
the avoidance of doubt, based on our review of discovery to date, the term “prosecution team”
means:
All personnel of the Special Counsel’s Office, irrespective of an assignment to aparticular investigation or matter;

The following components of the Department of Justice: Office of the Attorney
General, Office of the Deputy Attorney General, Office of Legal Counsel, National
Security Division, Public Integrity Section, and the United States Attorney’s Office forthe District of Columbia;



The National Archives and Records Administration, including but not limited to
NARA’s General Counsel’s Office, Office of the Inspector General, and White House
Liaison Division;

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 113 of
315
October 9, 2023
Page 2Members of the Intelligence Community, as that term is defined in 50 U.S.C. § 3003(4),including ODNI and the IC’s Office of the Inspector General;

In addition to those components of the FBI that are a part of the IC, the FBI’s
Washington Field Office and Miami Field Division; and

The White House Counsel’s Office.

Please let us know if you disagree about our inclusion of any particular agency or component in
the definition of the prosecution team.
II.

Requests

1.
Please provide all documents relating to security clearances, read-ins tocompartmented programs, non-disclosure agreements, and training relating to the handling ofclassified information that were signed by or provided to President Trump at any time before,
during, or after his time as President of the United States.
2.
following:With respect to the search warrant executed at Mar-a-Lago, please provide thea.
All documents relating to the planning and execution of the search,
including all sketches;b.
in logs; andc.

All documents relating to personnel present for the search, including signThe complete version of the photo log from the search.

3.
Please provide the FBI’s “database inventory of the classified documents” and alist of the “FBI-assigned index code[s]” used during the investigation, including the production
number of each document listed in the “database” and “index.” (See USA-00941764).
4.
Please provide all communications relating to concurrences obtained to use
documents during witness interviews.
5.
For each search warrant obtained in connection with the investigation, please
identify the “scoped” returns seized pursuant to the warrant by the Special Counsel’s Office or
DOJ.
6.
Please disclose all steps taken by the FBI’s Computer Analysis Response Team(CART) and Multimedia Exploitation Unit (MXU) in connection with CCTV from Mar-a-Lago,
including the use of any software to expedite the review.

Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

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October 9, 2023
Page 3

7.
Please disclose all steps taken by Deloitte in connection with the investigation,
including but not limited to the processing, handling, and review of evidence and other case-related
data.
8.
Please identify by production number the documents referenced in the FBI FD1057, titled “Corrections to Classification of Evidence Items” and bearing production number
USA-00950313.
9.
Please describe the scope and basis of the FBI’s declassification of certain caserelated records on or about June 5, 2023. (See, e.g., USA-00940000 (“Declassified By: NSICGOn 06-05-2023”)).
10.
Please provide a description of the following documents, including the author ofthe document, when the document was created, and the purpose of the document:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
11.
documents:

USA-00940116;
USA-00940123;
USA-00940131;
USA-00940152;
USA-00940156;
USA-00940295;
USA-00940301;
USA-00940303;
USA-00941498 – 00941500; andUSA-00941506 – USA-00941509.

Please provide the enclosures and/or attachments referenced in the following FBI
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
p.
q.

USA-00950276;
USA-00950280;
USA-00939793;
USA-00940081;
USA-00940220;
USA-00940221;
USA-00940230;
USA-00940232;
USA-00940236;
USA-00940242;
USA-00940248;
USA-00940271;
USA-00940410;
USA-00940420;
USA-00940422;
USA-00940470;
USA-00940473;

Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 115 of
315
October 9, 2023
Page 4

r.
s.
t.
u.
v.
w.
x.
y.
z.
aa.
bb.
cc.
dd.
ee.
ff.
gg.
hh.
ii.
jj.
kk.
ll.
mm.
nn.
oo.
pp.
qq.
rr.
ss.
tt.
uu.
vv.
ww.

USA-00940477;
USA-00940486;
USA-00940490;
USA-00940492;
USA-00940497;
USA-00940533;
USA-00940539;
USA-00940550;
USA-00940555;
USA-00940557;
USA-00940659;
USA-00940737;
USA-00940752;
USA-00940762;
USA-00940765;
USA-00940904;
USA-00940912;
USA-00941287;
USA-00941309;
USA-00941316;
USA-00941325;
USA-00941327;
USA-00941352;
USA-00941451;
USA-00941784;
USA-00941967;
USA-00942279;
USA-00942366;
USA-00942518;
USA-00943088;
USA-00944069; andUSA-00944317.

12.
For the period from January 20, 2021 to the present, please provide allcommunications by or including any NARA personnel relating to:a.
The collection of records from President Trump and any other members of
President Trump’s administration;b.
NARA’s practices under, and application of, the Presidential Records Act
with respect to President Trump, other members of President Trump’s administration, andformer presidents and other members of those presidents’ administrations; andc.
NARA’s historical practices with respect to the collection of records fromformer presidents and other members of those presidents’ administrations.
Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

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October 9, 2023
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13.
Please identify all instances in which NARA has referred a matter to any otherfederal agency, including but not limited to DOJ, FBI, or a member of the IC (including IC-OIG)
pursuant to 44 U.S.C. § 2112(c), 44 U.S.C. § 2905(a), or any other authority.
14.
Please provide all documents relating to decisions pursuant to 44 U.S.C. § 2205(2),including documents relating to:a.
The FBI’s April 4, 2022 request to DOJ for “coordination with White HouseCounsel on this matter” (USA-00940483);b.
(id.); andThe “past practice” referenced in the FBI’s April 4, 2022 memorandumc.
“[T]he incumbent President’s request” referenced in the FBI’s April 4, 2022
memorandum (USA-00940484).
15.
Please provide all documents relating to the “authority obtained by the Departmentof Justice” for the FBI’s May 16, 2022 “operation” at NARA. (USA-00940546).
16.
With respect to the November 22, 2022 memorandum from the FBI to NARA’s
General Counsel bearing production number USA-00940729:
a.
Please explain the basis for the redaction of the first paragraph of thememorandum; andb.
Please provide or identify all materials that NARA provided in response to
the November 22, 2022 request, including (i) “All records or information demonstrating adeclassification decision by the 45th Presidential Administration,” (ii) “Initial and periodic
training for handling classified information for all White House personnel during the 45th
Presidential Administration,” (iii) “Signed classified non-disclosure agreements for all
White House personnel during the 45th Presidential Administration,” and (iv) “Initial andperiodic training for handling classified information for all White House personnel during
the 45th Presidential Administration.”
17.
Please provide all documents relating to the January 26, 2023 video conference
between the Special Counsel’s Office and NARA General Counsel Gary Stern, including but notlimited to any recording of the video conference itself and notes and memoranda relating to“compliance considerations.” (USA-00941291).
18.
With respect to the meeting on or about May 4, 2023 between the Special Counsel’s
Office, FBI, and NARA General Counsel Gary Stern:a.
Please identify by production number the “81 unclassified documents
responsive to Grand Jury Subpoena 42-0064” that were discussed during the meeting(USA-00943085); andBlanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 117 of
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Page 6b.
Please provide all documents relating to the discussion of “multiple legal
options relating to potential additional NARA records, that would ensure proper protocol .
. .” (id.).
19.
Please provide all documents relating to the February 2022 “Congressional
Inquiry” to NARA referenced in the email bearing production number USA-00309425.
20.
Please provide all documents stored in the FBI’s Guardian system relating to thiscase, including but not limited to:a.

Communications and submissions from or relating to NARA; andb.
FBI communications regarding the status of any open Guardian leads andmatters related to the investigation.
21.
Please provide all documents relating to Hillary Clinton’s mishandling of classified
information while serving as Secretary of State between 2009 and 2013, including all documents
reflecting assessments of any damage to national security interests and/or spills of classified
information.
22.
Please provide all documents relating to James Comey’s mishandling of classified
information relating to meetings with President Trump in 2017 Mr. Comey was serving as FBI
Director, including all documents reflecting assessments of any damage to national security
interests and/or spills of classified information.
23.
Please provide all documents relating to the July 15, 2021 New Yorker article titled“Letter From Biden’s Washington: ‘You’re Gonna Have a Fucking War’: Mark Milley’s Fight To
Stop Trump From Striking Iran,” including all documents reflecting assessments of any damage
to national security interests and/or spills of classified information. (USA-00370509).
24.
Please provide descriptions of all classified documents, and all documents bearingclassification markings, that were seized or otherwise collected from Mike Pence, Joseph Biden,
and any other current or former elected federal official between January 2021 and the present.
25.
Please provide all documents relating to briefings—including briefings by DOJ,
FBI, and ODNI—to the Senate Intelligence Committee and the so-called “Gang of Eight” 1
regarding documents collected from Mike Pence and Joseph Biden, any other current or former
elected federal official.
26.
With respect to the February 28, 2023 “briefing” and related “G of 8” review
referenced in the discovery, please disclose the following:1

For purposes of this Request, “Gang of Eight” refers to one or more of Senator Chuck Schumer,
Senator Mitch McConnell, Senator Mark Warner, Senator Marco Rubio, Representative Kevin
McCarthy, Representative Hakeem Jeffries, Representative Mike Turner, and Representative Jim
Himes.
Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

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October 9, 2023
Page 939.
With respect to your representation to the Court that “all” witness statements havebeen produced, please confirm that your review of materials potentially subject to the Jencks Act
and Giglio has included all electronic facilities used by each witness, including both classified andunclassified email accounts, classified and unclassified chat and messaging programs, personal
email accounts, personal phones, and personal messaging apps.
We expect to submit additional questions and requests on a rolling basis. Please let us
know if you would like to discuss any of these issues.
Respectfully Submitted,/s/ Todd Blanche
Todd Blanche
Emil Bove
Stephen Weiss
Blanche Law PLLC
Christopher M. Kise
Chris Kise & Associates, P.A.
Attorneys for Donald J. Trump
Cc:

Sasha Dadan
Stanley Woodword
Counsel for Waltine Nauta(Via Email)John Irving
Larry MurrellCounsel for Carlos De Oliveira(Via Email)Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

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Ex. 26Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 122 of
315

TODD BLANCHE
Todd.Blanche@blanchelaw.com(212) 716-1250

November 1, 2023
Via EmailJay Bratt
Julie EdelsteinDavid Harbach
Senior Assistant Special Counsels
950 Pennsylvania Avenue NW
Room B-206
Washington, D.C. 20530
Re:

United States v. Donald J. Trump, No. 23 Cr. 80101 (AMC)

Dear Mr. Bratt, Ms. Edelstein, and Mr. Harbach:
We write on behalf of President Trump, pursuant to Rule 16(a)(1)(E), Brady, and Giglio,
to request the documents and information set forth below.
I.

Background

Each of the Requests set forth below calls for production of documents irrespective of theirclassification level. As used herein, the term “documents” includes (i) all communications,
including memoranda, reports, letters, notes, emails, text messages, and other electronic
communications; (ii) hard copies and electronically stored information, whether written, printed,
or typed; and (iii) all drafts and copies.
The Requests call for specified documents in the possession of the prosecution team, as we
defined that term in our October 9, 2023 letter.
II.

Requests

1.
Please provide all documents—including all drafts and all communications—relating to the June 28, 2023 memorandum bearing production number USA-01116848, including:a.
The “Information provided by the Office of Environment, Health, Safety
and Security (EHSS) and documents reviewed by the Office of General Counsel,” as referenced
in the June 28, 2023 memorandum; andb.
Any documents relating to “amend[ing]” or “modif[ying] President
Trump’s “active Q clearance,” as referenced in the June 28, 2023 memorandum.

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 123 of315
November 1, 2023
Page 22.
Please provide all documents relating to policies, procedures, practices, anddeterminations under Section 145 of the Atomic Energy Act of 1954 and Department of Energy
Redelegation Order No. 00-002.18 with respect to presidents who held office prior to President
Trump.
3.
Please provide all documents from the Department of Energy’s Central Personnel
Clearance Index relating to President Trump, including documents reflecting President Trump’s
listed status as of January 21, 2021, August 8, 2022, and June 8, 2023.
4.
Please provide all documents from the Department of Energy’s Central Action
Tracking System relating to President Trump, including documents reflecting President Trump’s
listed status as of January 21, 2021, August 8, 2022, and June 8, 2023.
5.
Please provide all documents from the Scattered Castles database relating to
President Trump, including documents reflecting President Trump’s listed status as of January 21,
2021, August 8, 2022, and June 8, 2023.
6.
Please provide all files from the Joint Personnel Adjudication System relating to
President Trump, including documents reflecting President Trump’s listed status as of January 21,
2021, August 8, 2022, and June 8, 2023.
7.
Please provide all documents relating to the February 28, 2022 meeting between
NARA personnel and staff from Congresswoman Carolyn Maloney and/or the House Committee
on Oversight and Reform.
8.
Please provide all documents—including all drafts and all communications—relating to the May 10, 2022 letter from Debra Steidel Wall to Evan Corcoran bearing production
number USA-00820773.
9.

Please provide all documents relating to:a.
Audits, assessments, analyses, after-action reports, and any similar
document reviewing or analyzing the collection of records from administrations prior to President
Trump’s first presidency by NARA or pursuant to the Presidential Records Act.
b.
NARA OIG Report No. 20-AUD-03, titled “Audit of NARA’s Classified
Information Systems.”c.
NARA OIG Report No. 19-MA-05, titled “Management Alert – Classified
Systems Lack Proper Authorization to Operate.”d.

NARA OIG Report No. 19-R-11, titled “Accessioning Expected Records.”e.
NARA OIG Report No. 18-AUD-04, titled “Office of the Federal Register’s
Administration of the Electoral College Process.”
Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

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November 1, 2023
Page 420.
Please identify the legal authority, if any, used to collect the NARA records
beginning at production number USA-01123490.
21.
Please identify the basis for the redactions in the document bearing production
number USA-00942878.
22.
documents:

Please provide the enclosures and/or attachments referenced in the following FBI
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
p.
q.
r.
s.
t.
u.
v.
w.
x.
y.
z.
aa.
bb.
cc.
dd.
ee.
ff.
gg.
hh.
ii.
jj.

USA-00942455;
USA-00942459;
USA-00942461;
USA-00942467;
USA-00942490;
USA-00942492;
USA-00942496;
USA-00942518;
USA-00942590;
USA-00942598;
USA-00942677;
USA-00942279;
USA-00942331;
USA-00942893;
USA-00944069;
USA-00944317;
USA-00944408;
USA-00944516;
USA-00944564;
USA-00950135;
USA-00944025;
USA-00944317;
USA-00944408;
USA-00944516;
USA-00950276;
USA-00950279;
USA-00950280;
USA-00950280;
USA-00950283;
USA-01123456;
USA-01123461;
USA-01123463;
USA-01123466;
USA-01275216;
USA-01275217; andUSA-01275284.

Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 126 of315
November 1, 2023
Page 5

We expect to submit additional questions and requests on a rolling basis. Please let us
know if you would like to discuss any of these issues.
Respectfully Submitted,/s/ Todd Blanche
Todd Blanche
Emil Bove
Stephen Weiss
Blanche Law PLLC
Christopher M. Kise
Chris Kise & Associates, P.A.
Attorneys for Donald J. Trump
Cc:

Sasha Dadan
Stanley Woodword
Counsel for Waltine Nauta(Via Email)John Irving
Larry MurrellCounsel for Carlos De Oliveira(Via Email)Blanche Law PLLC
99 Wall Street, Suite 4460 | New York, NY 10005(212) 716-1250 | www.BlancheLaw.com

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Ex. 27

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 128 of
315
U.S. Department of JusticeSpecial Counsel’s Office

October 16, 2023
Todd Blanche, Esq.
Emil Bove, Esq.
Stephen Weiss, Esq.
Blanche Law
Via email
Chris Kise, Esq.
Chris Kise & Associates, P.A.
Via emailRe:

United States v. Donald J. Trump, et al., Case No. 23-CR-80101(s)Dear Counsel:
We write in response to your discovery letter, dated October 9, 2023, which makes 39
discovery requests, some of which include multiple sub-parts. Many of your requests call for
information that has already been produced, and in instances where they call for specificdocuments that we have already produced, we identify the documents for you by Bates number.
Many other requests are follow-up questions regarding documents that we have produced far inexcess of our discovery obligations. See, e.g., USA-0000941498-00941509 (documents related to
the FBI’s review of CCTV footage; defense has equal access to the footage); USA-00940248(documenting the conversion of the FBI’s investigation into what the FBI terms a “fullinvestigation”); USA-0090483-USA-00940484 (documenting a request from FBI to DOJ for
assistance); USA-00941747-USA-00941749 (email chain regarding overtime approval for FBI
agents); USA-00941912-USA-00941913 (report and notes regarding a conversation with counsel
to discuss compliance with a grand jury subpoena that issued the same day). That we haveexceeded our discovery obligations by no means obligates the Government to produce additional
information that is not discoverable. To the extent that we are producing any additional
information to you in response to the discovery requests in your October 9, 2023 letter, we do so
notwithstanding the Government’s belief that such production exceeds its current discovery
obligations.
Regarding the query at the outset of your letter, we disagree with how you define theprosecution team. Your definition is overly broad. The prosecution team consists of theprosecutors of the Special Counsel Office and law enforcement officers of the Federal Bureau of
Investigation (FBI) who are working on this case, including members of the FBI’s Washington
Field Office and Miami Field Division. The prosecution team does not include agencies andcomponents whose personnel are not working on this case. For that reason, as we stated in
response to your prior question about the scope of the prosecution team, the National Archives andRecords Administration (NARA), the U.S. Secret Service, and the White House are not part of theCase 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 129 of315

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9. Your request does not call for material that is discoverable under Rule 16. Nonetheless,we hereby inform you that pursuant to FBI policy, certain documents were classified dueto their association with this case and/or file type, although the contents of the documents
themselves were not classified. The FBI declassified such documents in anticipation of theGovernment seeking an indictment in this case to facilitate the production of the documents
in discovery.
10. The request calls for material that is not discoverable under Rule 16, such as a “description”
of and the “purpose” of documents. The Government has produced all material to which
the defense is entitled regarding these documents. Nonetheless, we hereby inform you that
documents referenced in 10a. through 10h. relate to inventories of the boxes seized at Mara-Lago on August 8, 2022, pursuant to a court-authorized search warrant. On June 21,2023, the Government informed defense counsel that they could contact the Government
to arrange for inspection of unclassified items seized at Mar-a-Lago on August 8, 2022.
See ECF No. 30. The Government hereby further informs you that the documents
referenced in 10.i. through 10.j. are draft documents related to the FBI’s review of CCTV
footage.
11. The responses to the multiple sub-parts of your request are provided below.
a. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability. We haveconducted a review of notes from meetings with the Intelligence Community. All
discoverable information was provided to you with Classified Discovery Production
3, and no information from these notes was deemed discoverable.
b. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability. We haveconducted a review of notes from meetings with the Intelligence Community. All
discoverable information was provided to you with Classified Discovery Production
3, and no information from these notes was deemed discoverable.
c. The attachments were provided to you at USA-00816009-USA-00816126 andUSA-00825340-USA-00825476.
d. We are producing with this letter at USA-01285201-USA-01285206 the inventoryof the documents the Government obtained on June 3, 2023, in response to a May 11,2023 grand jury subpoena. The documents themselves were provided to you inClassified Discovery Production 1.
e. The referenced letter was provided to you at USA-00944017-USA-00944020. It isalso publicly available athttps://www.archives.gov/files/foia/wall-letter-to-evan-corcoran-re-trump-boxes05.10.2022.pdf

4Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 132 of
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f. The inventory was provided to you at USA-00940767-USA-00940822. The subsetof the NARA inventory was provided to you at USA-00940823-00940826. We areproducing with this letter at USA-01285223-USA-01285282 unredacted versions ofboth inventories.
g. The referenced enclosed items were provided to you at:
1.
2.
3.
4.
5.

Item 33 Box A-33: USA-00940156-USA-00940163
Item 32 Box A-13: USA-00940166-USA-00940171
Item 31 Box A-43: USA-00940311-USA-00940315
Item 30 Box A-26: USA-00940131-USA-00940135
Item 28 Box A-73 and Item 29 Box A-14: USA-00940152- USA00940155
6. Item 27 Box A-71: USA-00940140-USA-00940141
7. Item 26 Box A-42: USA-00940317-USA-00940349
8. Item 25 Box A-41: USA-00940164-USA-00940165
9. Item 24 Box A-40: USA-00940301-USA-00940302
10. Item 23 Box A-39: USA-00940357-USA-00940361
11. Item 20 Box A-22: USA-00940306-USA-00940310
12. Item 19 Box A-23: USA-00940173-USA-00940176
13. Item 18 Box A-35: USA-00940303-USA-00940305
14. Item 17 Box A-32: USA-00940350-USA-00940351
15. Item 16 Box A-30: USA-00940123-USA-00940128
16. Item 15 Box A-28: USA-00940352-USA-00940356
17. Item 14 Box A-27: USA-00940368-USA-00940373
18. Item 13 Box A-18: USA-00940142-USA-00940151
19. Item 12 Box A-17: USA-00940295-USA-00940300
20. Item 11 Box A-16 USA-00940374-USA-00940383
21. Item 10 Box A-15: USA-00940116-USA-00940122
22. Item 9 Box A-12: USA-00940177-USA-00940186
23. Item 8 Box A-1: USA-00940362-USA-00940367
24. Item 5: USA-00940136-USA-00940139
25. Item 4: USA-00940187-USA-00940198
26. Item 2: USA-00940199-USA-00940212
27. Item 1, 3, 6, 7: USA-00940316
28. Evidence Report for Case: USA-00940234-USA-00940235
h. The referenced enclosure is duplicative of g above.
i. The enclosure was provided to you at USA-00940839-USA-00940841.
j. The enclosed logs were provided to you at USA-00042642-USA-00042647 andUSA-00042649. The enclosed sketches were provided to you at USA-00042655USA-00042656. The enclosed CD contents were provided to you at USA-00042657
and USA-00042658-USA-00042659.

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k. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
l. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
m. We are producing with this letter at USA-01285209-USA-01285215 the enclosure.
n. We are producing with this letter at USA-01285307-USA-01285309 the scanned
versions of the hard-copy documents that were attached to the specified form.
o. The attachments were provided to you at USA-00940423-USA-00940441.
p. The enclosures were provided to you at USA-00940472 and USA-00940823-USA00940826. We are producing with this letter at USA-01285216-USA-01285219 anunredacted version of the subset of the inventory.
q. We are producing with this letter at USA-01285220-USA-01285222 the referenced
notes.
r. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
s. The enclosures were provided to you at USA-00940487-USA-00940489 and USA00800183-USA-00800201.
t. The referenced recording was provided to you at USA-00815949.
u. The referenced notes were provided to you at USA-00800202-USA-00800209.
v. The brief inventory was provided to you at USA-00940823-00940826. The
detailed inventory was provided to you at USA-00940767-USA-00940822. We areproducing with this letter at USA-01285223-USA-01285282 unredacted versions ofboth inventories.
w. We are producing to you in classified discovery at classified Bates Numbers 53725386 the notes.
x. The referenced notes were produced to you at USA-00814513-USA-00814520.
y. The email relaying the classified document counts was provided to you at USA00940953-USA-00940958. We are producing with this letter the spreadsheet at USA01285283.

6

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z. The referenced maps/diagrams were produced to you at USA-00042657 and USA00042658-USA-00042659.
aa. It is unclear what you are seeking in this request, but to the extent that you areseeking the boxes seized during the search warrant, they are available for yourinspection.
bb. The referenced recording was provided to you at USA-00819446.
cc. The referenced documents were provided to you in classified discovery at classified
Bates numbers 0220-0225.
dd. The items provided to the Government by Trump’s attorney on January 5, 2023,
are available for inspection.
ee. We are producing with this letter at USA-01285207 the referenced email.
ff. The inventory was provided to you at USA-00940767-USA-00940822. The subsetof the NARA inventory was provided to you at USA-00940823-00940826. We areproducing with this letter at USA-01285223-USA-01285282 unredacted versions ofboth inventories.
gg. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
hh. The contents of the referenced logbooks were provided to you at USA-00788281USA-00788364.
ii. The referenced certification was provided to you at USA-00805544.
jj. The referenced interview materials were provided to you at USA-00820233-USA00820236 and USA-00824954-USA-00824957.
kk. The agents notes and the recording from this interview were provided to you at
USA-00815848-USA-00815855 and USA-00815677, respectively.
ll. We are producing with this letter at USA-01285208 the referenced notes.
mm.
The referenced notes were provided to you at USA-00826230-USA00826237.
nn. We are producing with this letter at USA-01285195-USA-01285199 the enclosed
email.

7

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 135 of315

oo. The enclosures were provided to you at USA-00941453 and USA-941454. The
referenced “Google Map Print Out” was provided to you at USA-00750358-USA00750359. As explained in the letter accompanying unclassified Production 2, therelevant contents of the referenced hard drive were provided to you at USA-00958032USA-01115988.
pp. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
qq. The referenced email correspondence was provided to you at USA-00942009USA-00942010.
rr. The referenced materials provided by Mr. Per. 18 were provided to you at USA00041491-USA-00041510.
ss. The enclosed certification and exhibits were provided to you at USA-00387555USA-00387566; USA-00651017-USA-00651020; USA-00651021-USA-00651044;
USA-00651045-USA-00651050; and USA-00651051-USA-00651065.
tt. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
uu. The referenced transcript was provided to you at USA-00810700-USA-00810803.
The remainder of your request does not appear to call for the production of information
to which the defense is entitled. Please explain the defense’s theory of discoverability.
vv. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
ww.
We are producing with this letter at USA-01285171-USA-01285172 thereferenced email correspondence.
12. The Government has already produced all responsive material to which the defense isentitled. As we have conveyed, NARA is not part of the prosecution team, and we haveproduced all discoverable materials the Government obtained from NARA in its
investigation of this matter. (See Letter dated September 22, 2023.)
13. The request for “identif[ication]” of NARA referrals does not call for material that is
discoverable under Rule 16. We have produced all materials to which you are entitledregarding NARA and this matter. Please explain your theory of discoverability regarding
NARA referrals in connection with other matters.
14. The Government has already produced all responsive material to which the defense isentitled.

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315

15. The Government has already produced all responsive material to which the defense isentitled.
16. The responses to the multiple sub-parts of your request are provided below.
a. We are producing with this letter at USA-01285284-USA-01285285 the documentwith the first paragraph unredacted.
b. The Government has provided to you the materials at USA-00383394-USA00383403, USA-00383404, USA-01261484-USA-01261485, USA-01261486-USA01261487, USA-01261498, USA-01261548-USA-01261550, and USA-00383405464.
17. The Government has already produced all responsive material to which the defense isentitled.
18. The responses to the multiple sub-parts of your request are provided below.
a. The documents at issue are the same documents provided to you listed at 16.b.,above.
b. The Government has already produced all responsive material to which the defense
is entitled.
19. The Government has already produced all responsive material to which the defense isentitled.
20. The Government has already produced all responsive material to which the defense isentitled.
21. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
22. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
23. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
24. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
25. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.

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315

26. The Government has already produced all responsive material to which the defense isentitled.
27. Your request for a “description” of the FBI investigation addressed at USA-00941747USA-00941749 and USA-00941750-USA-00941752 does not call for material that is
discoverable under Rule 16. In any event, you are not entitled to material about other FBI
investigations.
28. The Government has already produced all responsive material to which the defense isentitled.
29. The Government has already produced all responsive material to which the defense isentitled.
30. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
31. The Government has already produced all responsive material to which the defense isentitled.
32. Your request does not call for material that is discoverable under Rule 16.
33. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
34. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
35. As you know, an FBI FD-302 report memorializes an interview. The December 9, 2022
conversation was not an interview, but a conversation with counsel related to a grand jury
subpoena that issued the same day. The Government was not under any obligation tomemorialize the conversation because no discoverable information was provided, yet the
FBI did so, and even though not discoverable, the Government provided to counsel thememorialization (USA-0041912-USA-0041913). The responses to the multiple sub-partsof your request are provided below.
a. The request does not call for material that is discoverable under Rule 16.
b. The Government has already produced all responsive material to which the defense
is entitled.
c. The Government has already produced all responsive material to which the defense
is entitled.

10

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36. Your request for “other instances” does not call for material that is discoverable under Rule
16. In any event, the Government has already produced all material to which the defense
is entitled relating to this request.
37. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
38. As we have stated, we are in compliance with our discovery obligations. We are also awareof, and will comply with, our continuing duty to disclose newly discovered additional
information required by this Court’s Standing Discovery Order, Rule 16(c) of the Federal
Rules of Criminal Procedure, Brady, Giglio, Napue, and the obligation to assure a fair trial.
39. As we have stated, we are in compliance with our discovery obligations. We are also awareof, and will comply with, our continuing duty to disclose newly discovered additional
information required by this Court’s Standing Discovery Order, Rule 16(c) of the Federal
Rules of Criminal Procedure, Brady, Giglio, Napue, and the obligation to assure a fair trial.
Yours truly,
JACK SMITH
Special Counsel
By:s/ Julie A. Edelstein
Julie A. Edelstein
Senior Assistant Special Counsel
Jay I. BrattCounselor to the Special Counsel
David V. Harbach, II
Assistant Special Counsel

cc: Stanley Woodward, Esq.
Brand Woodward Law
Via emailSasha Dadan, Esq.
Dadan Law Firm, PLLC
Via emailJohn Irving, Esq.
E & W Law
Via emailLarry Donald Murrell, Jr., Esq.
Via email11Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 139 of315

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315
U.S. Department of JusticeSpecial Counsel’s Office

October 30, 2023
Todd Blanche, Esq.
Emil Bove, Esq.
Stephen Weiss, Esq.
Blanche Law
Via email
Chris Kise, Esq.
Chris Kise & Associates, P.A.
Via emailRe:

United States v. Donald J. Trump, et al., Case No. 23-CR-80101(s)Dear Counsel:
We write in response to your classified discovery letter, dated October 19, 2023, which theClassified Information Security Officer (CISO) delivered to us at the end of the day on Friday,
October 20. Although our letter refers to classified material, this letter on its own is unclassified
because it does not reveal the substance of that material. If the information in this letter is used ina way that reveals the substance of classified information, that use must be consistent with the
CIPA Section 3 protective order. Your letter makes 43 discovery requests, some of which include
multiple sub-parts. Many of your requests call for information that has already been produced,
and in instances where they call for specific documents that we have already produced, we identify
the documents for you by Bates number. To the extent that we are producing any additional
information to you in response to the discovery requests in your October 19, 2023 letter, we do so
notwithstanding the Government’s belief that such production exceeds its current discovery
obligations.
As we explained in our October 16, 2023 response to your October 9 discovery letter, wedisagree with the overly broad way you define the prosecution team. We respond to your requests
below using the numbering from your letter.
1. The Government has already produced all responsive material to which the defense is entitled.
To the extent you are requesting publicly available information, that information is equallyaccessible to the defense, and your request does not call for information that is discoverable
under Rule 16. To the extent that you are requesting information related to the actions of any
U.S. government personnel, your request does not appear to call for the production of material
to which the defense is entitled; please explain the defense’s theory of discoverability. In
addition, we note that your requests are broader in most instances than the information in the
charged documents and that the portions of the charged documents you appear to reference inyour requests at 1e., 1f., 1i., 1j., 1k., 1l., and 1y. are not—as we informed you in our CIPA

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Section 10 notice—portions of the documents that we will rely on at trial to establish thenational defense element at trial.
2. As this request refers to topics identified in Request 40, and we do not see a list of topics
identified in Request 40, we do not understand your request.
3. As the first part of your request refers to topics identified in Request 40, and we do not see alist of topics identified in Request 40, we do not understand the first part of your request.
Nevertheless, as this request calls for information that is equally accessible to the defense, yourrequest does not call for material that is discoverable under Rule 16.
4. The Government has already produced all responsive material to which the defense is entitled.
5. The responses to the multiple sub-parts of your request are provided below.
a. The referenced documents were provided to you at classified Bates numbers 00060007.
b. The referenced document is not in the possession of the prosecution team.
c. The referenced documents were provided to you at classified Bates numbers 01860197.
d. The referenced document was provided to you at classified Bates numbers 01860197.
e. The referenced document was provided to you at classified Bates numbers 01860197.
f. The referenced document was provided to you at classified Bates number 2198.
g. The referenced document was provided to you at classified Bates number 2198.
h. The referenced document was provided to you at classified Bates number 0013.
i. The referenced document is not in the possession of the prosecution team.
j. The referenced document was provided to you at classified Bates number 2196.
k. The referenced document was provided to you at classified Bates numbers 948951.
l. The referenced document was provided to you at classified Bates number 956.
m. The referenced document was provided to you at classified Bates numbers 958959.

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n. The referenced document was provided to you at classified Bates number 956.
o. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability.
p. The referenced document was provided to you at classified Bates number 0272.
q. The referenced document was provided to you between classified Bates numbers
1915-1963.
r. The referenced documents were provided to you between classified Bates numbers
1915-1963.
s. The referenced document was provided to you at classified Bates number 2196.
t. The referenced document was provided to you at classified Bates number 2196.
u. The referenced documents were provided to you between classified Bates numbers
1915-1963.
v. The referenced documents were provided to you between classified Bates numbers
1915-1963.
w. The referenced documents were provided to you between classified Bates numbers
1915-1963.
x. The referenced documents were provided to you between classified Bates numbers
1915-1963.
y. The referenced document was provided to you at classified Bates number 0006.
z. The referenced document was provided to you at classified Bates numbers 54275431.
aa. Your request does not appear to call for the production of material to which thedefense is entitled. Please explain the defense’s theory of discoverability. In
addition, any records in the possession of NARA are available to Trump and his
Presidential Records Act representatives.
bb. We are uncertain as to the scope of the materials you are requesting, but in any
event, your request does not appear to call for the production of material to which
the defense is entitled. Please explain the defense’s theory of discoverability. In
addition, any records in the possession of NARA are available to Trump and his
Presidential Records Act representatives.

3

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cc. We are uncertain as to the scope of the materials you are requesting, but in any
event, your request does not appear to call for the production of material to which
the defense is entitled. Please explain the defense’s theory of discoverability. In
addition, any records in the possession of NARA are available to Trump and his
Presidential Records Act representatives.
dd. The referenced document was provided to you at classified Bates number 0005.
ee. The referenced documents were provided to you at classified Bates numbers 00060007.
ff. The referenced document was provided to you at classified Bates numbers 54275431.
gg. The referenced document was provided to you at classified Bates numbers 54275431.
hh. The referenced documents were provided to you at classified Bates numbers 0001
and 0013.
6. The referenced document is not in the possession of the prosecution team. Although the
document at classified Bates number 0003 was seized during the August 8, 2022 execution of
the court-authorized search warrant, the referenced attachment was not.
7. The referenced documents are not in the possession of the prosecution team.
8. We provided to you at classified Bates range 3842-3878 documents related to Count 27. We
have identified an additional three-page document responsive to your request. It will be
produced in a forthcoming classified discovery production.
9. We are uncertain as to the scope of the materials you are requesting, but in any event, yourrequest does not appear to call for the production of material to which the defense is entitled.
Please explain the defense’s theory of discoverability. In addition, any records in thepossession of NARA are available to Trump and his Presidential Records Act representatives.
10. The Government has already produced all responsive material to which the defense is entitled.
11. The Government has already produced all responsive material to which the defense is entitled.
12. The Government has already produced all responsive material to which the defense is entitled.
13. The defense is equally capable of matching produced photographs to produced documents.
Nonetheless, the Government provides below the classified Bates number for each document
depicted in a photograph on Disc 003:

4

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Photograph number on Disc 003
1038
1039
1040
1041
1042
1043
1044
1045
1046
1047
1048
1051
1052
1053
1054
1055
1059
1060
1063
1064
1067
1068
1069
1070
1071
1072
1073
1074
1075
1076
1077
1078
1079
1080
1081
1082
1083
1084
1085
1086
1087
1088
1089

Classified Bates number for document
0240
0240
0240
0238
0237
0014
0014
0014
0236
0236
0236
2202
0241
0241
0234
0234
2201
2201
0232
0232
0231
0231
0231
0230
0230
0229
0229
2205
2205
0252
2206
2206
0242
0242
0272
0272
0245
0251
0250
0249
0248
0246
0247

5

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14. The Government has already produced all responsive material to which the defense is entitled.
15. No responsive documents are within the possession of the prosecution team.
16. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
17. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
18. Your request for us to “identify” documents does not call for material that is discoverable under
Rule 16 of the Federal Rules of Criminal Procedure. Nonetheless, the Government informs
you that the Government submitted all documents with classification markings that were stored
at Mar-a-Lago for a classification review (although not necessarily the process described in thematerials at classified Bates numbers 3522-3538, as the Government is uncertain as to what“process” you are intending to refer).
19. The Government has already produced all responsive material to which the defense is entitled.
20. To the extent you are referring to communications related to the classification reviews
conducted regarding documents at issue in this case, the Government has already produced all
responsive material to which the defense is entitled. To the extent that you are referring tocommunications unrelated to this case, your request does not appear to call for the productionof material to which the defense is entitled; please explain the defense’s theory of
discoverability.
21. The referenced email was provided to you at classified Bates numbers 3982-3984.
22. The Government has already produced all responsive material to which the defense is entitled.
23. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
24. Your request for us to “identify” documents does not call for material that is discoverable under
Rule 16 of the Federal Rules of Criminal Procedure.
25. The Government has already produced all responsive material to which the defense is entitled.
26. The attachments were provided to you at classified Bates numbers 0295 (Enclosure 1); 0240
(Enclosure 2); 0241 (Enclosure 3); 2275 (Enclosure 4); 0237 (Enclosure 5); and 0230
(Enclosure 6).
27. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability. Nonetheless, the Government
provided at classified Bates range 3842-3878 documents related to Count 27, which is
described in the document at classified Bates range 3076-3077 as “Document 3.”6Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 146 of
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28. Standing alone, the email at classified Bates number 3080 is unclassified and may be handled
as such. However, the document described in the email is classified, and if the email isassociated with the classified document in a way that reveals anything about the content of theclassified document, the email must also be handled in accordance with the CIPA Section 3
protective order.
29. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
30. No documents responsive to your request exist.
31. The “Attachment” was provided to you at classified Bates numbers 3157-3158.
32. The attachments were provided to you at classified Bates numbers 0008, 0252, 0005, 0263,
5424, and 2199.
33. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
34. The responses to the multiple sub-parts of your request are provided below.
a. The Government has already produced all responsive material to which the defense isentitled.
b. Your request for us to “identify” documents does not call for material that is discoverable
under Rule 16 of the Federal Rules of Criminal Procedure. Nonetheless, we inform youthat all the documents the Government recovered from Mar-a-Lago—through Trump’sJanuary 2022 production to NARA, through the June 3, 2022 subpoena response, andthrough the August 8, 2022 search warrant—were among the documents considered in theInitial Assessment.
c. The request to “identify” information does not call for material that is discoverable under
Rule 16 of the Federal Rules of Criminal Procedure. Nonetheless, we inform you that thethree referenced criminal investigations include this investigation and two others.
d. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
e. The request to “identify” information does not call for material that is discoverable under
Rule 16 of the Federal Rules of Criminal Procedure. Nonetheless, we inform you thereferenced documents relate to one of the other criminal investigations, not this one.
35. The Government has already produced all responsive material to which the defense is entitled.

7

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36. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
37. Your request to “describe” “investigative steps” does not call for material that is discoverable
under Rule 16 of the Federal Rules of Criminal Procedure.
38. The Government has already produced all responsive material to which the defense is entitled.
In particular, if an attachment matches a document stored at Mar-a-Lago later recovered by theGovernment, the document has been produced.
39. The email cited at classified Bates number 4003 does not appear to be truncated or cut off, andas a result, the Government is not sure to what email threads you are referring. Please clarify
your request.
40. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
41. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
42. It is not clear to what materials you are referring in this request, but to the extent that responsive
materials are in the prosecution team’s possession, the Government has already produced all
responsive material to which the defense is entitled.
43. The Government has already produced all responsive material to which the defense is entitled.
Yours truly,
JACK SMITH
Special Counsel
By:s/ Julie A. Edelstein
Julie A. Edelstein
Senior Assistant Special Counsel
Jay I. BrattCounselor to the Special Counsel
David V. Harbach, II
Assistant Special Counsel

cc: Stanley Woodward, Esq.
Brand Woodward Law
Via email8Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 148 of
315

Sasha Dadan, Esq.
Dadan Law Firm, PLLC
Via emailJohn Irving, Esq.
E & W Law
Via emailLarry Donald Murrell, Jr., Esq.
Via email9Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 149 of
315

Ex. 29Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 150 of
315
U.S. Department of JusticeSpecial Counsel’s OfficeNovember 8, 2023
Todd Blanche, Esq.
Emil Bove, Esq.
Stephen Weiss, Esq.
Blanche Law
Via email
Chris Kise, Esq.
Chris Kise & Associates, P.A.
Via emailRe:

United States v. Donald J. Trump, et al., Case No. 23-CR-80101(s)Dear Counsel:
We write in response to your discovery letter, dated November 1, 2023, which makes 22
discovery requests, some of which include multiple sub-parts. Many of your requests call for
information that has already been produced, and in instances where they call for specificdocuments that we have already produced, we identify the documents for you by Bates number.
In addition, in the email accompanying your discovery letter, you informed us that thebracketed references to Request 40 in your October 19 letter were in error, and you intended thoserequests to refer to the list in Request 1. As a result of that clarification, we inform you that our
response to your second request in that letter is that we have already provided all responsive
material to which the defense is entitled, and the response to your third request in that letter remains
the same—that is, as this request calls for information that is equally accessible to the defense,
your request does not call for material that is discoverable under Rule 16. You also asked us toprovide a disc with an electronic copy of the classified index that we produced to the Atkins SCIF
on October 19. We will provide to the CISO the electronic copy for delivery to the SCIF.
We respond to your requests below using the numbering from your letter, defining theprosecution team as we set forth in our October 16 letter.
1. The Government has already produced all responsive material to which the defense isentitled.
2. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
3. No such documents are in the possession of the prosecution team (except to the extent that
previously produced material is considered responsive).

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4. No such documents are in the possession of the prosecution team (except to the extent that
previously produced material is considered responsive).
5. The responsive documents in the prosecution team’s possession were provided to you at
USA-00950293-USA-00950295.
6. No such documents are in the possession of the prosecution team.
7. There are no responsive documents in the possession of the prosecution team.
8. The Government has already produced all responsive material to which the defense isentitled.
9. There are no responsive documents in the possession of the prosecution team.
10. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
11. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
12. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
13. The Government has already produced all responsive material to which the defense isentitled. In particular, the Government produced a risk assessment at classified Bates
numbers 3513-3521.
14. The Government has already produced all responsive material to which the defense isentitled.
15. The referenced document is not in the possession of the prosecution team. In addition, anysuch records in the possession of NARA are available to Trump and his Presidential
Records Act representatives.
16. The referenced attachment was provided to you at USA-00383607-USA-00383608.
17. The referenced “List of Records” was provided to you at USA-00417576.
18. The referenced PowerPoint was provided to you at USA-00370431-USA-00370442.

2

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r. The Government has produced all responsive material to which the defense isentitled. The Government produced responsive material at USA-01285174-USA01285194, USA-01285173, and USA-00940557.
s. The enclosures aside from the email notification were provided to you at USA00944567-USA-00944572. The description of Enclosure 1 was labeled “July 1, 2021”
in error and should instead read “July 24, 2021” as referenced elsewhere in the form.
Your request for the email notification to DOJ does not appear to call for the
production of material to which the defense is entitled. Please explain the defense’s
theory of discoverability.
t. The enclosed notes were provided to you at USA-00950138.
u. The Government has produced all responsive material to which the defense isentitled. Specifically, the Government has produced the underlying documents related
to Mr. Per. 18 at USA-00944026-USA-00944027, USA-00804663-USA-00804825,
USA-00805861-USA-00806075, USA-00807756-USA-00807847, USA-00821698USA-00821753, USA-00814510-USA-00814512, USA-00827493 - USA-00827509,
USA-00821779-USA-00821941, USA-00809172-USA-00809418, and USA00820082-USA-00820136.
v. Your request is a duplicate of your request at 22p. Please see our response to 22p.,
above.
w. Your request is a duplicate of your request at 22q. Please see our response to 22q.,
above.
x. Your request is a duplicate of your request at 22r. Please see our response to 22r.,
above.
y. Your request is a duplicate of request 11a. in your October 9, 2023 letter. Pleasesee our October 16, 2023 response.
z. The notes referenced in this request are the same notes requested in request 11a. inyour October 9, 2023 letter. Please see our October 16, 2023 response.
aa. Your request is a duplicate of request 11b. in your October 9, 2023 letter. Pleasesee our October 16, 2023 response.
bb. Your request is a duplicate of your request at 22aa. and request 11b. in your October
9, 2023 letter. Please see our October 16, 2023 response.
cc. The notes referenced in this request are the same notes requested in your requests
at 22.aa. and 22bb. and request 11b. in your October 9, 2023 letter. Please see ourOctober 16, 2023 response.

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John Irving, Esq.
E & W Law
Via emailLarry Donald Murrell, Jr., Esq.
Via email7

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Ex. 30Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 158 of
315
U.S. Department of JusticeSpecial Counsel’s OfficeNovember 8, 2023
Todd Blanche, Esq.
Emil Bove, Esq.
Stephen Weiss, Esq.
Blanche Law
Via email
Chris Kise, Esq.
Chris Kise & Associates, P.A.
Via emailRe:

United States v. Donald J. Trump, et al., Case No. 23-CR-80101(s)Dear Counsel:
We write in response to your classified discovery letter, dated October 31, 2023, which theClassified Information Security Officer (CISO) delivered to us on November 1. Although ourletter refers to classified material, this letter on its own is unclassified because it does not reveal
the substance of that material. If the information in this letter is used in a way that reveals thesubstance of classified information, that use must be consistent with the CIPA Section 3 protective
order. Your letter makes six discovery requests, some of which include multiple sub-parts.
We respond to your requests below using the numbering from your letter.
1. The Government has already produced all responsive material to which the defense is entitled.
The Government also notes that the identification number referenced in your request 1a. does
not appear on the document at classified Bates number 2219.
2. The referenced document was provided to you on Disc_004, in the folder titled “1B8 Laptop”;
the document is page 497 of file titled “2018 Dailys Part 1 (01.02.18 – 06.29.18)
Combined.pdf.”
3. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
4. The Government has already produced all responsive material to which the defense is entitled.
In particular, the Government provided to you at classified Bates range 2969-3462 documents
related to the classification review process.

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5. Your request for us to “describe” the “classification review” process does not call for material
that is discoverable under Rule 16 of the Federal Rules of Criminal Procedure. The
Government reiterates that it provided to you at classified Bates range 2969-3462 documents
related to the classification review process.
6. Your request does not appear to call for the production of material to which the defense isentitled. Please explain the defense’s theory of discoverability.
Yours truly,
JACK SMITH
Special Counsel
By:s/ Julie A. Edelstein
Julie A. Edelstein
Senior Assistant Special Counsel
Jay I. BrattCounselor to the Special Counsel
David V. Harbach, II
Assistant Special Counsel

cc: Stanley Woodward, Esq.
Brand Woodward Law
Via emailSasha Dadan, Esq.
Dadan Law Firm, PLLC
Via emailJohn Irving, Esq.
E & W Law
Via emailLarry Donald Murrell, Jr., Esq.
Via email2Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 160 of315

Ex. 31Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 161 of315

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Ex. 32

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Ex. 33

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Ex. 34

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315
Olsen, Matthew (NSD)
Subject:
Location:

Search Warrant Discussion
FBIHQ (b)(7)(E) per FBI

Start:End:
Show Time As:

Monday, August 1, 2022 10:30 AM
Monday, August 1, 2022 11:15 AM
Tentatively accepted

Recurrence:(none)

Meeting Status:

Not yet responsed

Organizer:
Required Attendees:

Olsen, Matthew (NSD)
Newman, David A. (ODAG); Bratt, Jay (NSD); Toscas, George (NSD); Jones,
Jason Allen (OGC) (FBI); Kohler, Alan E. Jr. (CD) (FBI); Riedlinger, Anthony
T. (WF) (FBI); D'Antuono, Steven Michael (WF) (FBI)Freedman, Brett (NSD); (b)(6),(b)(7)(C) per NSD (NSD)

Optional Attendees:

Document ID: 0.7.498.45621

01715-03354

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FBI 10Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 174 of315

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Ex. 37

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Ex. 38Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 180 of
315Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 181 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 182 of315

Ex. 39Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 183 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 184 of
315<(b)(6),(b)(7)(C) per NSD
Subject: CNN - Mar-a-Lago CCTV Footage
Importance: HighGood evening all,I just received a call from our case agents at FBI, and apparently the Bureau has
been given a heads-up by CNN that CNN has CCTV footage from Mar-a-Lago(presumably of agents executing the search) that they may air as soon as
tonight (b)(5) per NSD

I have no further info on what, specifically, CNN has. But (b)(5) per NSD(b)(6),(b)(7)(C) per NSD

Trial Attorney
Counterintelligence and Export Control Section
National Security Division, U.S. Department of Justice
Washington, D.C. 20530(b)(6),(b)(7)(C) per NSD

Document ID: 0.7.500.35523

01715-01051

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Ex. 40Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 186 of315

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Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 188 of315

Ex. 41Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 189 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 190 of315

Ex. 42

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 191 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 192 of
315

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Ex. 43

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 194 of
315
From:
Subject:
To:
Sent:
Attached:

Newman, David A. (ODAG)
08.17.22 Letter
Toscas, George (NSD)
August 17, 2022 8:50 PM (UTC-04:00)
08.17.22 Letter .docx

Draft version for editing

Document ID: 0.7.500.35541

01715-01067

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Ex. 44

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 196 of
315
From:
Subject:
To:
Cc:
Sent:
Attached:

Newman, David A. (ODAG)
LetterBratt, Jay (NSD)
Toscas, George (NSD)
August 17, 2022 8:48 PM (UTC-04:00)
Letter -- 08.17.22.pdf

See attached PDF. This letter reflects the concerns shared with us this evening from FBI about threats and safety totheir personnel. FBI leadership is grateful for the willingness to send this letter. I know you’ve been in touch with
George about this letter and appreciate your reviewing and sending.
--David

Document ID: 0.7.500.35542

01715-01066

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 197 of315

Ex. 45Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 198 of
315
From:
Subject:
To:
Cc:
Sent:

Bratt, Jay (NSD)
FW: News Media intervention in Trump v. United States, No. 22-civ-81294
Gonza ez, Juan Antonio (USAFLS)(b)(6),(b)(7)(C) per NSD(NSD); Toscas, George (NSD); Newman, David A. (ODAG)
August 30, 2022 9:59 AM (UTC-04:00)

Tony:
I don’t think (b) (5)Thoughts (including
those cc’d)?
Jay
From: Mark R. Caramanica <mcaramanica@tlolawfirm.com>
Sent: Tuesday, August 30, 2022 9:54 AM
To: Gonzalez, Juan Antonio (USAFLS) (b)(6) per EOUSA @usa.doj.gov>; Bratt, Jay (NSD) <(b)(6),(b)(7)(C) per NSD
Cc: Dana J. McElroy <DMcElroy@tlolawfirm.com>
Subject: [EXTERNAL] News Media intervention in Trump v. United States, No. 22-civ-81294
Dear Messrs. Gonzalez and Bratt:On behalf of a news media coalition (comprising many of the same entities who intervened before Judge
Reinhart regarding the search warrant materials), we plan to file a motion today to intervene in this matter as well. We
will be opposing any sealing of records filed under seal pursuant to the Court’s August 27, 2022 order (ECF No. 29).
Please let us know your position on: 1) intervention and 2) whether the United States will oppose unsealing of thoserecords. We are happy to discuss if you’d like.
Thank you.
-Mark Caramanica
Mark R. Caramanica
60 South Boulevard
Tampa, FL 33606(b) (6)

ph: 8 3 984 3060 direct
fax: 8 3 984 3070 toll free: 866 395 7 00
www tlolawfirm com
Member of NAMWOLF®

Tampa South Florida
To upload large documents, please click here
CONFIDENTIALITYNOTICE: The nfo mat on conta ned n th s ema message s ntended fo the pe sona and conf dent a use of the ec p ent(s) des gnated above Th smessage may conta n nfo mat on that s p v eged, conf dent a and exempt f om d sc osu e unde app cab e aw and any unautho zed o nadve tent use, ece pt,
d sc osu e, d ssem nat on, o d st but on of such nfo mat on sha not wa ve any such p v ege If you a e not an ntended ec p ent of th s message, and/o you haveece ved th s message n e o , then p ease not fy the sende at (8 3) 984-3060 Any unautho zed and/o un ntended ev ew, use, d ssem nat on, d st but on, o ep oduct onof th s message, o any of the nfo mat on conta ned n t, s st ct y p oh b ted

Document ID: 0.7.500.36107

01715-02304

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Ex. 46Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 200 of
315
From:
Subject:
To:
Cc:
Sent:

Bratt, Jay (NSD)
Fwd: from counse for Media Intervenors/search warrant matterCo ey, Anthony D. (PAO); Rosse o, Luis (PAO)
Osen, Matthew (NSD); Toscas, George (NSD); Newman, David A. (ODAG)
August 24, 2022 7:30 PM (UTC-04:00)

FYI
Begin forwarded message:

From: "Gonzalez, Juan Antonio (USAFLS)"(b)(6) per EOUSA @usa.doj.gov>
Date: August 24, 2022 at 7:27:23 PM EDT
To: "Tobin, Charles D." <TobinC@ballardspahr.com>
Cc: "Bratt, Jay (NSD)" <(b)(6),(b)(7)(C) per NSD
Subject: RE: from counsel for Media Intervenors/search warrant matter

Hi Chuck,
Sorry for the delay getting back to you but I have been tied up today. We are planning to follow the
Court’s order and file our pleadings under seal. We do not intend to make a public filing however, theJudge may want to make public specific parts of our pleading.
Regards,
Tony

Juan Antonio Gonzalez
United States Attorney
Southern District of Florida
99 NE 4th Street
Miami, Florida 33132
305-961-9100

From: Tobin, Charles D. <TobinC@ballardspahr.com>
Sent: Wednesday, August 24, 2022 8:44 AM
To: Gonzalez, Juan Antonio (USAFLS (b)(6) per EOUSA @usa.doj.gov>
Subject: [EXTERNAL] from counsel for Media Intervenors/search warrant matter
Good morning, Tony, I hope you remain well. I wanted to check on the government’s plans for
tomorrow’s noon filing, per the Court’s order.
We presume the government will file two versions of the legal memorandum containing its arguments forthe continued sealing of portions of the search warrant affidavit one version sealed, the other a redacted
public version. If you would confirm, we would appreciate it. Thank you.
Chuck

Document ID: 0.7.500.35726

01715-01505

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315

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Ex. 47

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 203 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 204 of
315

This is a very well written order. Clearly written for the media/public and not really for the lawyers.
Contains nothing new.
TonyJuan A. Gonzalez
U.S. Attorney
Southern District of Florida
Begin forwarded message:
From: cmecfautosender@flsd.uscourts.gov
Date: August 22, 2022 at 7:49:38 AM EDT
To: flsd_cmecf_notice@flsd.uscourts.gov
Subject: Activity in Case 9:22-mj-08332-BER USA v. Sealed Search Warrant Order

This is an automatic e-mail message generated by the CM/ECF system. Please DO
NOT RESPOND to this e-mail because the mail box is unattended.
***NOTE TO PUBLIC ACCESS USERS*** There is no charge for viewing opinions.
U.S. District Court
Southern District of Florida
Notice of Electronic Filing
The following transaction was entered on 8/22/2022 at 7:48 AM EDT and filed on 8/22/2022
Case Name:
USA v. Sealed Search Warrant
Case Number:
9:22-mj-08332-BER
Filer:
Document Number:80

Docket Text:
ORDER as to Sealed Search Warrant, memorializing and supplementing
oral rulings at August 18, 2022, hearing. Signed by Magistrate Judge Bruce
E. Reinhart See attached document for full details. (BER)
9:22-mj-08332-BER-1 Notice has been electronically mailed to:
Andrea Flynn Mogensen andrea@sarasotacriminallawyer.com, records@flcga.org
Carol Jean LoCicero clocicero@tlolawfirm.com, nparsons@tlolawfirm.com,
tgilley@tlolawfirm.com
Charles David Tobin tobinc@ballardspahr.com, baileys@ballardspahr.com,
LitDocket_East@ballardspahr.com, relyear@ballardspahr.com, tom.winter@nbcuni.com,
tranp@ballardspahr.com
Dana Jane McElroy dmcelroy@tlolawfirm.com, bbrennan@tlolawfirm.com,

Document ID: 0.7.500.35637

01715-01143

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 205 of315

tgilley@tlolawfirm.com
Deanna Kendall Shullman dshullman@shullmanfugate.com, abeene@shullmanfugate.com,
pleadings@shullmanfugate.com
Elizabeth Seidlin-Bernstein SeidlinE@ballardspahr.com
Eugene Branch Minchin mminchin@shullmanfugate.com, abeene@shullmanfugate.com,
pleadings@hullmanfugate.com
James Calvin Moon jmoon@melandbudwick.com, ltannenbaum@ecf.courtdrive.com,
ltannenbaum@melandbudwick.com, mrbnefs@yahoo.com, phornia@ecf.courtdrive.com
Juan Antonio Gonzalez , Jr juan.antonio.gonzalez@usdoj.gov, CaseView.ECF@usdoj.gov,
USAFLS-HQDKT@usdoj.gov, wanda.hubbard@usdoj.gov
L. Martin Reeder , Jr martin@athertonlg.com, e-service@athertonlg.com,
tracey@athertonlg.com
Mark Richard Caramanica mcaramanica@tlolawfirm.com, bbrennan@tlolawfirm.com,
dlake@tlolawfirm.com
Michael Bekesha mbekesha@judicialwatch.org
Nellie Linn King Nellie@CriminalDefenseFla.com, Anne@CriminalDefenseFla.com
Paul J. Orfanedes porfanedes@judicialwatch.org
Rachel Elise Fugate rfugate@shullmanfugate.com, abeene@shullmanfugate.com,
pleadings@shullmanfugate.com
9:22-mj-08332-BER-1 Notice has not been delivered electronically to those listed below
and will be provided by other means. For further assistance, please contact our Help Desk
at 1-888-318-2260.:
The following document(s) are associated with this transaction:

Document description:Main Document
Original filename:n/a
Electronic document Stamp:[STAMP dcecfStamp_ID 1105629215 [Date 8/22/2022] [FileNumber 224862920] [871089e550bf8eb1e2cd0a56c1dbe293e7a4e8c2a152333ba4038c98a2a03dc029
0d29a9487297d1a12d777aed57e6465d3bab491d96394fdfa6ea1519956518]]

Document ID: 0.7.500.35637

01715-01144

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Ex. 48Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 207 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 208 of
315

Department of Justice(b)(6) per OLC(cell)(office)
From: Lederman, Martin (OLC)
Sent: Monday, August 29, 2022 3:23 PM
To: Newman, David A. (ODAG) <(b) (6)(OLC) (b)(6) per OLC>
Cc: Evers, Austin (ODAG) <(b) (6)<(b) (6)
Subject: Re: time-sensitive(b) (5) questions

Schroeder, Christopher H.
Atkinson, Lawrence (ODAG)

Gary pinged me again. Everyone ok with me conveying our current view?
Sent from my iPhone

Duplicative Records

Document ID: 0.7.500.8600

01715-02311

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Ex. 49Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 210 of
315
From:
Subject:
To:
Cc:
Sent:

Lederman, Martin (OLC)
Re: time-sensitive (b) (5) questions
Evers, Austin (ODAG)
Newman, David A. (ODAG); Schroeder, Christopher H. (OLC); Atkinson, Lawrence (ODAG)
August 29, 2022 3:38 PM (UTC-04:00)

Ok, but if there’s a way to settle on it today, that’d be great. I suppose that in the meantime I could simply tell Garythat we are considering the question.
Sent from my iPhone
On Aug 29, 2022, at 3:26 PM, Evers, Austin (ODAG) <(b) (6)wrote:

Please hold (b) (5)
From: Lederman, Martin (OLC) (b)(6) per OLC
Sent: Monday, August 29, 2022 3:23 PM
To: Newman, David A. (ODAG) <(b) (6)(b)(6) per OLC
Cc: Evers, Austin (ODAG) <(b) (6)<(b) (6)
Subject: Re: time-sensitive (b) (5) questions

Schroeder, Christopher H. (OLC)
Atkinson, Lawrence (ODAG)

Gary pinged me again. Everyone ok with me conveying our current view?
Sent from my iPhone
On Aug 29, 2022, at 9:13 AM, Lederman, Martin (OLC) <(b)(6) per OLC
wrote:
I agree, too. And I’ll add this:(b)(5) per OLC

Document ID: 0.7.500.36010

01715-02258

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 211 of315(b)(5) per OLC
How does that sound? Should I (b) (5)?

Marty Lederman
Deputy Assistant Attorney General
Office of Legal Counsel
Department of Justice(b)(6) per OLC (cell)(b)(6) per OLC (office)
From: Newman, David A. (ODAG) <(b) (6)
Sent: Monday, August 29, 2022 8:42 AM
To: Schroeder, Christopher H. (OLC) <(b)(6) per OLC; Lederman,
Martin (OLC) (b)(6) per OLC>
Cc: Evers, Austin (ODAG) <(b) (6)Atkinson, Lawrence (ODAG)<(b) (6)
Subject: RE: time-sensitive(b) (5) questions
Thanks, Chris. That makes sense (b) (5).
From: Schroeder, Christopher H. (OLC) <(b)(6) per OLC
Sent: Monday, August 29, 2022 8:15 AM
To: Lederman, Martin (OLC) (b)(6) per OLC; Newman, David A. (ODAG)<(b) (6)
Cc: Evers, Austin (ODAG) <(b) (6)Atkinson, Lawrence (ODAG)<(b) (6)
Subject: RE: time-sensitive (b) (5) questions
On the question of (b)(5) per OLC
is (b)(5) per OLC

Document ID: 0.7.500.36010, my first instinct

01715-02259

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 212 of315(b)(5) per OLC

From: Lederman, Martin (OLC) (b)(6) per OLC
Sent: Sunday, August 28, 2022 11:23 PM
To: Newman, David A. (ODAG) <(b) (6)
Cc: Schroeder, Christopher H. (OLC) <(b)(6) per OLC
Atkinson, Lawrence (ODAG)(ODAG) <(b) (6)<(b) (6)
Subject: RE: time-sensitive(b) (5) questions

Evers, Austin(b)(5) per OLC
Marty Lederman
Deputy Assistant Attorney General
Office of Legal Counsel
Department of Justice(b)(6) per OLC (cell)(b)(6) per OLC (office)
From: Newman, David A. (ODAG) <(b) (6)
Sent: Sunday, August 28, 2022 11:19 PM
To: Lederman, Martin (OLC) <(b)(6) per OLC
Cc: Schroeder, Christopher H. (OLC) <(b)(6) per OLC
Atkinson, Lawrence (ODAG)(ODAG) <(b) (6)<(b) (6)
Subject: Re: time-sensitive (b) (5) questions

Document ID: 0.7.500.36010

Evers, Austin

01715-02260

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 213 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 214 of315(b)(5) per OLC.
I’ll be on the road much of tomorrow (Monday), but could talk if necessary.
Thanks.

Marty Lederman
Deputy Assistant Attorney General
Office of Legal Counsel
Department of Justice(b)(6) per OLC (cell)(b)(6) per OLC (office)Document ID: 0.7.500.36010

01715-02262

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 215 of315

Ex. 50Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 216 of315

FBI 26Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 217 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 218 of315

Ex. 51Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 219 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 220 of
315

Per. 12Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 221 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 222 of315

Ex. 52

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 223 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 224 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 225 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 226 of315

Ex. 53

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 227 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 228 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 229 of315

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315

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315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 233 of
315

Ex. 54

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 234 of
315

FBI 35Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 235 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 236 of
315

Ex. 55Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 237 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 238 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 239 of315

Ex. 56Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 240 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 241 of
315

Ex. 57

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 242 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 243 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 244 of
315

Ex. 58Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 245 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 246 of
315

Ex. 59Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 247 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 248 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 249 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 250 of
315

Per. 32

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 251 of
315

Ex. 60Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 252 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 253 of
315

Ex. 61Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 254 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 255 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 256 of
315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 257 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 258 of315

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 259 of315

Ex. 62

010213Case
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Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 265 of315

Ex. 63

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 266 of
315

January 12, 2024
Mr. Nathan J. Wade, Esq.
Nathan J. Wade, P.C. Attorney at Law
d/b/a Wade & Campbell Firm
1827 Powers Ferry Road
Building 25, Suite 100
Atlanta, GA 30339
Dear Mr. Wade:
The Committee on the Judiciary continues to conduct oversight of politically motivatedprosecutions by state and local officials. Based on recent reports, we believe that you possess
documents and information about the coordination of the Fulton County District Attorney’s
Office (FCDAO) with other politically motivated investigations and prosecutions and thepotential misuse of federal funds. Accordingly, we ask for your cooperation with our oversight.
On August 14, 2023, with your assistance, Fulton County District Attorney Fani T. Willis
indicted a former President of the United States and current declared candidate for that office.1
According to a recent court filing, you have been paid more than $650,000—at the rate of $250
per hour—to serve as an “Attorney Consultant” and later a “Special Assistant District Attorney”
in the unprecedented investigation and prosecution of the former President and other former
federal officials.2 This filing also alleges that while receiving a substantial amount of moneyfrom Fulton County, you spent extravagantly on lavish vacations with your boss, Ms. Willis.3
Although Ms. Willis has so far refused to cooperate with our oversight of the FCDAO’s
coordination with other politically motivated prosecutions, invoices that you submitted for
payment by the FCDAO, and made public as part of this court filing, highlight this collusion.
This new information appears to substantiate our concerns that Ms. Willis’s politicizedIndictment, Georgia v. Donald John Trump, et al., No. 23SC188947 (Aug. 14, 2023, Fulton Co. Sup. Ct.).
Defendant Michael Roman’s Motion to Dismiss Grand Jury Indictment as Fatally Defective and Motion to
Disqualify the District Attorney, Her Office and the Special Prosecutor from Further Prosecuting this Matter at 11,
Georgia v. Donald John Trump, et al., No. 23SC188947 (Jan. 8, 2024, Fulton Co. Sup. Ct.) (“Roman Motion”).
3
Id. at 26-27.
12

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 267 of
315
Mr. Nathan J. Wade, Esq.
January 12, 2024
Page 2
prosecution, including the decision to convene a special purpose grand jury, was aided bypartisan Democrats in Washington, D.C.4 For example:•

In April 2022, you billed $6,000 for 24 hours of “[t]eam meeting; Conf w/Jan 6;
Research legal issues to prep intev” from April 18 to 22.5•

In May 2022, you billed $2,000 for eight hours of “travel to Athens; conf. with WhiteHouse Counsel” on May 23, 2022.6•

In that same invoice, you billed another $2,000 for eight hours of “team meeting; Conf
w/Jan 6; SPGJ witness prep” on May 31, 2022.7•

In September 2022, you billed $6,000 for 24 hours of “[w]itness [i]nterviews; conf call
DC; team meeting” from September 7 to 9.8•

In November 2022, you billed $2,000 for eight hours of “Jan 6 meeting and Atty
conf.” on November 16.9•

In that same invoice, you billed another $2,000 for eight hours of “[i]nterview with
DC/White House” on November 18.10

The FCDAO reportedly compensated you using a concoction of comingled funds,
including monies confiscated or seized by the FCDAO and monies directed from Fulton
County’s “general” fund.11 The Committee has information that the FCDAO received
approximately $14.6 million in grant funds from the Department of Justice between 2020 and202312 and, given the enormous legal fees you have billed to the FCDAO, there are open
questions about whether federal funds were used by the FCDAO to finance your prosecution. In
fact, on one day—November 5, 2021—you billed taxpayers for 24 hours of legal work, attestingthat you worked all day and night without break on a politically motivated prosecution.
A recent news report corroborates your coordination with partisan Democrats, explainingthat you and FCDAO staff “quietly met” with the partisan January 6 Committee, which allowed

Letter from Rep. Jim Jordan, Chairman, H. Comm. on the Judiciary, to Dist. Att’y Fani T. Willis, Fulton Co. Dist.
Att’y’s Off. (Dec. 5, 2023) (“December Letter”).
5
Id. at Ex. F (invoice #6).
6
See id. at Ex. F (invoice #8); Josh Boswell, Invoices from lawyer ‘lover’ hired by Fani Willis to prosecute Donald
Trump in election interference case show he had TWO 8-hour meetings with the Biden White House counsel,
DAILYMAIL.COM (Jan. 9, 2024).
7
Roman Motion, supra note 2, Ex. F (invoice #8).
8
Id. at Ex. F (invoice #12).
9
Id. at Ex. H (invoice #14).
10
See Roman Motion at Ex. F, Boswell, supra note 6.
11
Roman Motion at 13-16.
12Letter from Fani T. Willis to Rep. Jim Jordan, Chairman, H. Comm. on the Judiciary at Ex. E (Sept. 7, 2023).
4

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 268 of
315
Mr. Nathan J. Wade, Esq.
January 12, 2024
Page 3you to review information they had gathered.13 Politico reported that the partisan January 6
Committee provided Ms. Willis’s prosecution a “boost” as she prepared to convene a special
grand jury and even “helped prosecutors prepare for interviews with key witnesses.”14 The same
article suggests that the partisan January 6 Committee provided you access to records it withheld
from other law-enforcement entities and even other Members of Congress.15

The Committee has serious concerns about the degree of improper coordination among
politicized actors—including the Biden White House—to investigate and prosecute President
Biden’s chief political opponent. This new information released recently only reinforces theCommittee’s concerns about politically motivated prosecutions by state and local officials. To
advance our oversight, we ask that you please produce the following documents and information
for the period of November 1, 2021, to the present:
Betsy Woodruff, et al., Jan. 6 committee helped guide early days of Georgia Trump probe, POLITICO (Jan. 10,2024).
14
Id.
15
Id.
13

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 269 of
315
Mr. Nathan J. Wade, Esq.
January 12, 2024
Page 4
1. All documents and communications in your possession between or among the Fulton
County District Attorney’s Office, including yourself, and the U.S. Department of Justiceand its components, including but not limited to Special Counsel Jack Smith, referring or
relating to the Fulton County District Attorney’s Office’s investigation of President
Trump;
2. All documents and communications in your possession between or among the Fulton
County District Attorney’s Office, including yourself, and the Executive Office of the
President, including but not limited to the White House Counsel’s Office, referring or
relating to the Fulton County District Attorney’s Office’s investigation of President
Trump;
3. All documents and communications in your possession between or among the Fulton
County District Attorney’s Office, including yourself, and the partisan January 6 SelectCommittee referring or relating to the Fulton County District Attorney’s Office’s
investigation of President Trump;
4. All notes, memoranda, documents, or other material in your possession referring or
relating to your meetings, conferences, phone calls, or other interactions with the U.S.
Department of Justice, the Executive Office of the President, or the partisan January 6
Select Committee;
5. All invoices, including credit card statements and individualized reimbursement requests,
submitted by you or your law partners to the Fulton County District Attorney’s Office
relating to its investigation of President Trump; and6. All contracts and financial arrangements between you and the Fulton County District
Attorney’s Office relating to its investigation of President Trump.
Please provide this information as soon as possible but not later than 10:00 a.m. on January 26,
2024.
Pursuant to Rule X of the Rules of the House of Representatives, the Committee has
jurisdiction over criminal justice matters in the United States.16 If you have any questions about
this request, please contact Committee staff at (202) 225-6906. Thank you for your prompt
attention to this matter.
Sincerely,
Jim Jordan
Chairman
16

Rules of the House of Representatives, R. X, 118 th Cong. (2023).

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 270 of
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Mr. Nathan J. Wade, Esq.
January 12, 2024
Page 5cc:

The Honorable Jerrold L. Nadler, Ranking Member

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 271 of315

Ex. 64

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Ex. 65Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 293 of315

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Ex. 66Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 297 of315

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Per. 49

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Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 300 of315

Ex. 67

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 301 of
315
1
2
3
4

5

6

RECORDED INTERVIEW BETWEEN

7ASSISTANT SPECIAL COUNSEL DAVID RASKIN,

8SENIOR ASSISTANT SPECIAL COUNSEL JULIE EDELSTEIN,9ASSISTANT SPECIAL COUNSEL MARIA VENTO,

10

FBI SPECIAL AGENTFBI 21A

11

FBI SPECIAL AGENTFBI 20,, andPer. 49

12

,

,

13
14

File: 230222_001.mp3

15
16

Date: February 22, 2023

17
18
19
20
21
22

23
24
25
FREE STATE REPORTING, INC.
Court Reporting Transcription
D. C. Area 301-261-1902
Balt. & Annap. 410-974-0947

Subject to Protective Order

USA-00827517

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 302 32
of
315
1

(00:43:54)

Per. 49 :2-- lawyer and said, oh my gosh, I just3

got a call from the FBI what do I do?

4called5

who served

6

understand it and

7

I'll, I'll find Per. 34 a lawyer but it started with Per. 1 and8then it went to -- so they -- it's very individual,

9depending upon what -- which of the things they were being

10

contacted about, who they were -- does that -- do I answer

11

you?

12
13

Per. 16

who was a,he was a

as I.

MS. EDELSTEIN:

Yeah.

And he said

I'm curious how some of theother lawyers were, were located in this case as well.

Per. 49 :1415

And he found -- heso Per. 16

Okay.

,

So I'm doing this from memory,, Woodward

16

MS. EDELSTEIN:

Does someone recommend Woodward?

17

Per. 49 :, who was18

at the time but very much in the Trump family

Yes.

19

was one of the early people called and20

don't remember her last name -- the minority counsel in the21

house recommended Stanley for

22with his lawyer.

23

the circumstances were because P. 13 had been involved in so

24much -- but when25

should talk to Stanley Woodward.

and

(ph.)

was very happy

And so when they -- I don't remember what

Per. 13needed counsel, Per. 1 said you

FREE STATE REPORTING, INC.
Court Reporting Transcription
D. C. Area 301-261-1902
Balt. & Annap. 410-974-0947

Subject to Protective Order

USA-00827548

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 303 of315

Ex. 68Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 304 of
315
1
2
3

4
5

6

RECORDED INTERVIEW BETWEEN

7ASSISTANT SPECIAL COUNSEL DAVID RASKIN,

8FBI SPECIAL AGENT

FBI 3

FBI SPECIAL AGENT

910FBI 18Per. 49

,

,
,

and

11
12

File: 230407 0923.MP3

1323407 1028.MP3

1423407 1219.MP3

1523407 1329.MP3

16
17

Date:

April 7, 2023

18
19
20
21
22

23
24
25
FREE STATE REPORTING , INC .
Court Reporting Transcription
D.C. Area 301 - 261 -1 902
Balt . & Annap . 410 - 974 - 0947

Subject to Protective Order

USA-00827986

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 305 of
315
66
1

(00:35:48)
MR. RASKIN:

2-- vet Carlos before getting a3lawyer.

And by that I mean finding out sort of what the guy

4

is going to say, or what kind of guy he is --5

Per. 49 :6

MR. RASKIN:

or whether he's

7

Per. 49 :I already knew HIM

8

MR. RASKIN:

9Per. 49 :10

Oh, no.

You knew
Carlos.

I've been around Carlos a

lot.

11

MR. RASKIN:

But perhaps, okay, so this is August,12

you know, this is, you know, perhaps not in this context.

13

mean, yeah, it's one thing to know whether he can reliably,

14

you know, get the grill to where the President wants the15

grill.

I

It's another thing

16

Per. 49 :17

MR. RASKIN:

Which is how I knew him.
And I'm not, don't take this as aPer. 49

18

suggestion, but I'm, I'm paying for lawyers

19

here, there and everywhere, yeah, I know Carlos is the20

maintenance guy at Mar-a-Lago.

21

for a guy's lawyer if he's going to like, you know, sink the

22

ship.

23

former President of the United States, I'd like to know that24

before I'm the one who cuts his lawyer's check.

25

something --But like I don't want to pay

Like if he's going to be the guy who like undoes theIs that

FREE STATE REPORTING , INC .
Court Reporting Transcription
D.C. Area 301 - 261 -1 902
Balt . & Annap . 410 - 974 - 0947

Subject to Protective Order

USA-00828051

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 306 of
315
67
1

(00:36:56)

Per. 49 :2
3

I ca nnot say this equivocally enough,unequivocally enough, that is not so.

4

MR. RASKIN:

Yeah.

5

Per. 49 :Not so.

MR.

6
7

:

It's all the more reason to get alawyer.

8

MR. RASKIN:

And why are you so sure about that?

9Per. 49 :Because I have been cognizant since10

the beginning, ish, I don't know exactly what date, that it11

was important that we not, we being me mainly, we not value

12

somebody's knowledge or testimony as it relates to whether

13

we provided them counsel.

14

President would, that would be even more important to me.

15

MR. RASKIN:

And somebody that close to the

Basically what I think you're saying

16

is in

17

it is not your job to assess the nature of their potential

18

statements or testimony in making a decision about whether

19

to get them a lawyer, it's irrelevant?

Per. 49 :

20
21

,

cognizant that I should not.

22

MR. RASKIN:

23

Per. 49 :24

MR. RASKIN:

25

Not only is it not my job, I'm very

You've made a point not to do that?
Yes.
And the reason you're so adamant thatthat type of thing that I suggested didn't happen is it
FREE STATE REPORTING , INC .
Court Reporting Transcription
D.C . Area 301 - 261 -1 902
Balt . & Annap . 410 - 974 - 0947

Subject to Protective Order

USA-00828052

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 307 of315

Ex. 69Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 308 of
315

Previously Filed
Under Seal

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 309 of315

Ex. 70DECLASSIFIED BY

I 06-06-2023
Case 9:23-cr-80101-AMC~hia red.acted veraion onl

Document 469-1 Entered on FLSD Docket 04/22/2024 Page 310 of315(WF) (FBI)FBI 19. . . . . . . . . . (WF)(FBI)

From:
To:
Subject:
Date:~,8/8/22
Tuesday, August 09, 2022 2:43 :21 PM

To -

file

From: FBI 10(WF) {FBI)
Sent: Tuesday, August 9, 2022 11:00 AM

FBI 39To:

FBI 8{MM) (FBI)(MM) (FBI);(WF) (FBI)(MM) (FBI);FBI 12
FBI 34
FBI 1

FBI 19FBI 23(MM) (FBI){MM) (FBI)MM) (FBI)

Subject: Re: TEAM LEAD Thread, 8/8/22
I just wa nted to extend my t hanks again for everyone's help yest erday. We could not have asked foranything more. We'll done by all of you and yo ur teams.

FBI 10FBI/Washington Field Office

FBI 39From:(MM) (FBI)

Sent: Monday, August 8, 2022 10:35:04 PM
To:

FBI 8

. (MM) (FBI);(WF) (FBI)FBI 19;(WF) (FBI)FBI 10;(MM) (FBI)
FBI 1

;
;

FBI 12(MM) {FBI)(MM) (FBI)FBI 34(MM) {FBI)FBI 23

Subject: Re: TEAM LEAD Thread, 8/8/22
All,
Please let me know if I'm missing anyone that was present today.
Command

FBI 8
FBI 10WFO Case TeamFBI 19SA
FBI 21A
SA
FBI 9

SA

FBI 39FBI 1

Subject to Protective Order

USA-00940279

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 311 of
315
SA
SA
SA

FBI 28
FBI 31
FBI 22Filter team:
SA
SA
SA
SA

FBI 12
FBI 17
FBI 36
FBI 13FBI 5■ search team:
SA
SA

FBI 6
FBI 4

ERT
SA
SA
SA
SA

FBI 37
FBI 34
FBI 23
FBI 32
FBI 24■FBI 16SA

Auditor,FBIHQPMFBI 30
DOJ

Per. 23
Per. 6
Get some rest and take care,

FBI 39From:(MM) (FBI)FBI 39Sent: Monday, August 8, 2022 4:56:52 PM
To:

FBI 8

Subject to Protective Order(MM) (FBI)(WF) (FBI)FBI 19FBI 12 (MM) (FB I)(MM) (FBI)FBI 34

USA-00940280

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 312 of315; FBI 10

FBI 23;

FBI 1(WF) {FBI){FBI)

Subject: Re: TEAM LEAD Thread, 8/8/22

Please send anyone not actively working to the ballroom. Considering releasing some teammembers.

FBI 39From:(MM) (FBI)

Sent: Monday, August 8, 2022 4:33 :26 PM
To:

FBI 8

(MM) {FBI);(MM) (FBI)FBI12(MM) (FBI)FBI 34
FBI 1;

FBI 12 (MM) {FBI)(MM) (FBI)FBI 34
FBI 1

FBI 19FBI 10 (WF) (FBI)(MM) {FBI)FBI 23;(WF) (FBI);;

Subject: Re: TEAM LEAD Thread, 8/8/22

Residence is complete.

FBI 39From:(MM) (FBI)

Sent: Monday, August 8, 2022 2:07 :37 PM

FBI 8

To:

(MM) (FBI)(WF) (FBI)FBI 19>; FBI 10(WF) (FBI);(MM) (FBI)FBI 23
Subject: Re: TEAM LEAD Thread, 8/8/22

We are wrappi ng up the office. About to move to residence. Let yo ur t eams know.

FBI 8

From:

(MM) (FBI)

Sent: Monday, August 8, 2022 1:04:15 PM
To:

FBI 12

FBI 39(MM) (FBI);;(WF) {FBI)FBI 19(WF) (FBI)FBI 10(FBI)
FBI 23(MM) (FBI)FBI 34FBI 1{MM)

Subject: Re: TEAM LEAD Thread, 8/8/22

TTA is on scene and standing by in vehicle until needed.

FBI 8

From:

FBI 12(MM) (FBI)

Sent: Monday, August 8, 2022 11:35 :08 AM
To:

FBI 39(MM) (FBI)(MM) (FBI)(MM) (FBI)

Subject to Protective OrderFBI 8(MM) (FBI);FBI 19FBI 10FBI 23. (WF) {FBI)(WF) (FBI)FBI 34
FBI 1

USA-00940281

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 313 of315
Subject: Re: TEAM LEAD Thread, 8/8/22

Fi lter team is working at office location. F. 36has been sent to the first location. Do you need further
assistance?

FBI 12
(w)
(c)
From:

FBI 39{MM) {FBI)

Sent: Monday, August 8, 2022 11:00:45 AM
To:

FBI 8

(MM) {FBI)•;(MM) (FBI)FBI 12(WF)(FBI)
FBI 10(MM) (FBI)FBI 23;

FBI 19
FBI 34
FBI 1(WF) (FBI)(MM) (FBI)

Subject: Re: TEAM LEAD Thread, 8/8/22

Filter team has begun in second location. The order was switched t o begin at secon d location
inst ead of first.
From:

FBI 8

(MM) (FBI)

Sent: Monday, August 8, 2022 10:56:58 AM
To:

FBI 39{MM) (FBI)

(FBI)
;
;

FBI 12 (MM) (FBI)FBI 10 (WF) (FBI)MM) (FBI)FBI 23;

FBI 1

FBI 19(WF)(MM) (FBI)FBI 34

Subject: Re: TEAM LEAD Thread, 8/8/22

Need one free body back outside please

FBI 8

From:

FBI 39(MM) (FBI)

Sent: Monday, August 8, 202210:33 :05 AM
To:

FBI 8

MM) (FBI)FBI 12(FBI);(WF) (FBI)FBI 10>;(MM) (FBI)FBI 23

FBI 19
FBI 34
FBI 1(WF) (FBI)

Subject: Re: TEAM LEAD Thread, 8/8/22

We are beginning t he search .
From:

FBI 39(MM) (FBI)

Sent: Monday, August 8, 2022 10:29:48 AM

Subject to Protective Order

USA-00940282

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 314 of
315
FBI 8

To:

FBI 19
FBI 34
FBI 1(MM) (FBI)FBI 12 (MM) (FBI)FBI 10 (WF) (FBI)(MM) (FBI)FBI 23;;;(WF) (FBI)(MM) (FBI)(MM) (FBI)>

Subject: Re: TEAM LEAD Thread, 8/8/22
Please share with the group, CCTV is back on .

FBI 39From:(MM) (FB I)

Sent: Monday, August 8, 2022 9:52:05 AM

FBI 8

To:

(MM) (FBI)FBI 19
FBI 34
FBI 1;

FBI 12 (MM) (FBI)(WF) (FBI)FBI 10(MM) (FBI)FBI 23;(WF) (FBI)(MM) (FBI)

Subject: Re : TEAM LEAD Thread, 8/8/22
Fol low up call with the attorneys at 10am. We are working on CCTV. Standby.

FBI 8

From:

(MM) (FBI)>

Sent: Monday, August 8, 2022 9:36:40 AM
To:

FBI 19(WF) (FBI)(MM) (FBI)FBI 12
FBI 10 (WF) (FBI)(MM) (FBI)FBI 23

FBI 39;;~;(MM) (FBI)FBI 34
FBI 1(MM) (FBI)(MM) (FBI)

Subject: Re: TEAM LEAD Thread, 8/8/22
On phone with attorney. Stand by

FBI 8
From:

FBI 19(WF) (FBI)

Sent: Monday, August 8, 2022 9:14:39 AM
To:

FBI 39;(MM) (FBI)FBI 34;(MM) (FBI)FBI 10FBI 23(WF) (FBI);FBI 12
FBI 8
FBI 1(MM) (FBI)(MM). (MM) (FBI)

Subject: Re: TEAM LEAD Thread, 8/8/22
All,
We have called the attorney, no answ er. An email is being sent now .... per

FBI 8 , pleasestay flexible.
Thank you

Subject to Protective Order

USA-00940283

Case 9:23-cr-80101-AMC Document 469-1 Entered on FLSD Docket 04/22/2024 Page 315 of315
FBI 19From:(WF) (FBI)

Sent: Monday, August 8, 2022, 7:41 AM

FBI 39To:>;(MM) (FBI)FBI 34;(MM) (FBI)FBI 10;FBI 12
FBI 8
FBI 1(MM) (FBI)(MM)

Subject: Re : TEAM LEAD Thread, 8/8/22

Addi ng SA

FBI 1

Removing SA
Thank you,
F. 19

FBI 19From:. (WF) (FBI)

Sent: Monday, August 8, 2022, 7:36 AM
To:

FBI 19

FBI 39(WF) (FBI)>;FBI 12;(MM) (FBI);(MM) (FBI)FBI 10(MM) (FBI)FBI 34(MM) (FB I)

FBI 8(WF) (FBI)

Subject: TEAM LEAD Thread, 8/8/22

Good Morning,This is the t hread we will use for today's operation.This is an interna l thread only.
Thank you,

FBI 19Subject to Protective Order

USA-00940284