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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO. 22-CV-81294-CANNON

DONALD J. TRUMP,

Plaintiff,

v.

UNITED STATES OF AMERICA,

Defendant.

________________________________/

MOTION TO FILE AFFIDAVIT UNDER SEAL

The United States of America moves the Court to file under seal one document, the 

United States’ Affidavit Regarding Detailed Inventory (the “Affidavit”), which is made 

pursuant to the Special Master’s Case Management Plan (DE 112). In support of the 

Motion, the government states: 

1. Courts have inherent power to control access to papers filed with the courts. 

Nixon v. Warner Communications, Inc., 435 U.S. 589, 598 (1978). Courts have traditionally 

been “highly deferential to the government’s determination that a given investigation 

requires secrecy and that warrant materials be kept under seal.” Times Mirror Co. v. United 

States, 873 F.2d 1210 (9th Cir. 1989). Therefore, courts have routinely granted government 

requests to seal warrant materials where there is a need for secrecy. See Washington Post v. 

Robinson, 935 F.2d 282, 289 (D.C. Cir. 1991).

2. In a hearing on September 20, 2022, the Special Master gave permission for 

the government to redact the name of the FBI Supervisory Special Agent making the 

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Affidavit. On September 26, 2022, the government filed on the public docket a Notice of 

Filing that attached the redacted version of the affidavit and indicated it had filed a motion 

to seal the unredacted version (DE 116).1 The proposed sealed document is the unredacted 

version of the Affidavit. The redaction sought here will protect the identity of an FBI agent 

working on this investigation. This limited sealing is necessary because a number of the 

government personnel working on this investigation have, once their identities have been 

revealed publicly, been subject to threats and harassment. 

CONCLUSION

WHEREFORE, for these reasons, the United States of America respectfully requests 

that the Court issue an Order permitting the government to file under seal the government’s

unredacted Affidavit Regarding Detailed Inventory.

Dated: September 28, 2022 Respectfully submitted,

/s/ Julie A. Edelstein_______________________

Julie A. Edelstein

Deputy Chief

Counterintelligence and Export Control Section

National Security Division

United States Department of Justice

950 Pennsylvania Avenue, N.W.

Washington, DC 20530

Special Bar # A5502949

Tel.: 202-233-0986

Email: julie.a.edelstein@usdoj.gov

1 Pursuant to the Court’s Order in Docket Entry 116 and Southern District of Florida Local 

Rule 5.4, the government now files on the public docket this Motion. 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on September 28, 2022, I electronically filed the

foregoing document with the Clerk of the Court using CM/ECF. I also certify that the

foregoing document is being served this day on all counsel of record via transmission of

Notices of Electronic Filing generated by CM/ECF.

/s/ Julie A. Edelstein_______________________

Julie A. Edelstein

Deputy Chief

Counterintelligence and Export Control Section

National Security Division

United States Department of Justice

950 Pennsylvania Avenue, N.W.

Washington, DC 20530

Special Bar # A5502949

Tel.: 202-233-0986

Email: julie.a.edelstein@usdoj.gov

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