1 

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. 

________________________________/ 

[UNITED STATES’ PROPOSED] JUDICIAL PROTECTIVE ORDER

Following notice and opportunity to be heard, further to paragraph 19 of the Order 

dated September 15, 2022 [ECF No. 91], and upon review of the parties’ respective judicial 

protective orders [ECF Nos. ___ and ___], it is hereby 

ORDERED AND ADJUDGED as follows: 

1. Introduction and Basis for Judicial Protective Order. – The Court’s Order 

appointing the special master [ECF No. 91, ¶ 5] requires the government to provide copies 

of materials seized during the August 8, 2022 execution of a court-authorized search 

warrant at the premises located at 1100 S. Ocean Boulevard, Palm Beach, Florida 33480 

(the “Seized Materials”) to the Special Master, Plaintiff’s counsel, and certain agents and 

employees. The Seized Materials are evidence in a criminal investigation case, most of 

whose details are not a matter of public record. In addition, the Court’s order [ECF No. 91, 

¶ 5] requires the Parties to prepare logs based on and derived from the Seized Materials that 

should similarly be protected from public disclosure to facilitate the special-master-review 

Case 9:22-cv-81294-AMC Document 102 Entered on FLSD Docket 09/20/2022 Page 1 of 6
2 

process. To preserve the confidentiality of non-public information and protect the specialmaster-review process, the Court enters this Judicial Protective Order.1

 

2. Confidentiality and Non-Disclosure of Seized Materials and Undertakings 

on Exhibit A. – The Seized Materials produced by the government are confidential and 

shall be disclosed to no one other than the Special Master, his law clerks, admitted 

Plaintiff’s counsel of record in this case (“Plaintiff’s Counsel”), staff supporting Plaintiff’s 

Counsel (such as paralegal assistants, secretarial, stenographic, and clerical employees) who 

are working on this case under the direction of Plaintiff’s Counsel and to whom it is 

necessary that the Seized Materials be disclosed for purposes of executing this Court’s 

orders, and vendors approved by the Special Master or this Court for purposes of scanning, 

hosting, reviewing or otherwise processing electronic copies of Seized Materials. 

Plaintiff’s Counsel shall provide the government with the names and job titles of any 

staff who Plaintiff’s Counsel propose to review Seized Materials at least two business days 

before Seized Materials are shown to such persons and such persons must execute the 

“Acknowledgment of Protective Order” that is attached to this Judicial Protective Order at 

1

 This Judicial Protective Order does not govern Seized Materials with classification 

markings. The government contends that Seized Materials with classification markings 

should not be provided to the Special Master or Plaintiff’s counsel and has pending before 

the United States Court of Appeals for the Eleventh Circuit an application for a stay 

pending appeal. If the Eleventh Circuit stays this Court’s order with respect to documents 

with classification markings, this Judicial Protective Order will govern Seized Materials 

without classification markings. If any classified materials will ultimately be provided to 

Plaintiff’s counsel, then the parties will propose a separate judicial protective order for the 

Court to enter concerning documents with classification markings that is similar to a 

protective order pursuant to Section 3 of the Classified Information Procedures Act, 18 

U.S.C. App. III § 3. 

Case 9:22-cv-81294-AMC Document 102 Entered on FLSD Docket 09/20/2022 Page 2 of 6
3 

Exhibit A. If the government objects to disclosure during such two-day period, no Seized 

Materials may be disclosed until the government’s objection is resolved by the Court.2

Vendors who are engaged to scan, host, provide review, or otherwise process the 

electronic copies of the Seized Materials must also sign execute the “Acknowledgment of 

Protective Order” that is attached to this Judicial Protective Order at Exhibit A. 

3. Limitations on Use. – Plaintiff’s Counsel, their staff, and any vendors shall 

use Seized Materials exclusively in connection with the above-captioned case and not for 

any other purpose. Nothing herein shall prevent a party from using Seized Materials as 

exhibits to pleadings or otherwise, or from referring to, quoting, or reciting from Seized 

Materials in connection with pleadings or motions filed in the above-captioned case; 

provided, however, that any such Seized Materials be filed under seal or submitted to the 

Special Master or Court for in camera inspection. 

 4. Maintaining Copies of Seized Materials. – Plaintiff’s Counsel, their staff, 

and any vendors to whom the government provides Seized Materials shall maintain any 

Seized Materials produced pursuant to this Judicial Protective Order in a manner 

reasonably intended to preserve and maintain the confidentiality of the materials. 

Specifically, Plaintiff’s Counsel, their staff, and any vendors shall maintain Seized Materials 

in secure areas or on secure networks along with a copy of this Judicial Protective Order. If 

stored electronically on networks not owned by the government, Seized Materials shall be 

password-protected and the network folders in which they are stored shall be walled off 

from any individuals not directly assisting in the above-captioned case. 

2

 With respect to the Seized Materials, the government is separately bound by the Warrant 

and this Court’s order, which includes an injunction. 

Case 9:22-cv-81294-AMC Document 102 Entered on FLSD Docket 09/20/2022 Page 3 of 6
4 

 5. Unauthorized Disclosure. – If Plaintiff’s Counsel, their staff, or any vendor 

learns that it has disclosed, inadvertently or otherwise, Seized Materials to a person in a 

circumstance not authorized under this Judicial Protective Order or any unauthorized 

access to Seized Materials otherwise occurs, the disclosing party must immediately 

(a) notify the government in writing of the unauthorized disclosures, (b) use its best efforts 

to retrieve all unauthorized copies of the Seized Materials, (c) inform the person or persons 

to whom unauthorized disclosures were made of all the terms of this Judicial Protective 

Order, and (d) request such person or persons sign the “Acknowledgment of Protective 

Order” that is attached to this Judicial Protective Order at Exhibit A. 

6. Violations. – Violations of this Judicial Protective Order shall be punishable 

by contempt of court or any other legally available sanction that the Court deems 

appropriate. All parties to whom Seized Materials are disclosed in accordance with this 

Judicial Protective Order consent and submit to this Court’s jurisdiction for purposes of 

enforcing this order. 

7. Further Relief. – Nothing in this Judicial Protective Order shall be construed 

as restricting any party from seeking such further relief as may be available under applicable 

law. 

DONE AND ORDERED in Chambers at Fort Pierce, Florida, this ___ day of 

September 2022. 

 

AILEEN M. CANNON 

UNITED STATES DISTRICT JUDGE 

cc: counsel of record

Case 9:22-cv-81294-AMC Document 102 Entered on FLSD Docket 09/20/2022 Page 4 of 6
EXHIBIT A 

ACKNOWLEDGMENT OF JUDICIAL PROTECTIVE ORDER 

I hereby acknowledge that I received a copy of the Judicial Protective Order issued in 

Donald J. Trump v. United States of America, Case No. 22-CV-81294-CANNON (S.D. Fla.), that 

I read and understand it, and I agree to be bound by its terms. I further understand that by 

signing this Acknowledgment, I subject myself to the jurisdiction of the United States District 

Court for the Southern District of Florida for the purpose of enforcing the terms of the Judicial 

Protective Order and punishing any violations thereof. 

____________________________ 

Name (Printed) 

____________________________ 

Signature 

____________________________ 

Street Address 

____________________________ 

City, State, and Zip Code 

____________________________ 

Telephone Number 

____________________________ 

E-Mail Address 

Case 9:22-cv-81294-AMC Document 102 Entered on FLSD Docket 09/20/2022 Page 5 of 6
CERTIFICATE OF SERVICE 

 

I HEREBY CERTIFY that on September 20, 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 

Case 9:22-cv-81294-AMC Document 102 Entered on FLSD Docket 09/20/2022 Page 6 of 6