UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

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DONALD J. TRUMP,

Plaintiff,

INTERIM REPORT AND

- against - RECOMMENDATION NO. 1

No. 22-81294-CIV-CANNON

UNITED STATES OF AMERICA,

Defendant.

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RAYMOND J. DEARIE, Special Master

Pursuant to the Order Appointing Special Master, ECF 91 (“Appointing Order”), as 

amended by the Order Following Partial Stay, ECF 104, the undersigned respectfully submits 

this interim report and recommendation.

I. VERIFICATION OF THE DETAILED PROPERTY INVENTORY

Pursuant to the Amended Case Management Plan dated September 23, 2022, ECF 106

(“Amended Plan”), on September 26, 2022, the government submitted an Affidavit Regarding 

Detailed Inventory together with a Revised Detailed Property Inventory. ECF 116; see Amended 

Plan at 1-2. The information in the Revised Detailed Property Inventory differs in some respects 

from the information in the government’s previously filed Detailed Property Inventory. See ECF 

39-1. 

Plaintiff’s deadline for submitting a declaration or affidavit contesting the government’s 

inventory is currently scheduled for September 30, 2022. See Amended Plan at 1. However, in 

light of delays in retaining a vendor to digitize the Seized Materials, see ECF 112 (granting 

motion to extend time), Plaintiff’s deadline for submitting a declaration or affidavit in response 

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to the government’s revised inventory is extended to October 7, 2022. The government’s 

deadline to file a responsive declaration or affidavit remains set for October 14, 2022.

II. REVIEW OF SEIZED MATERIALS

In light of delays in selecting a document review vendor, see ECF 108, the undersigned 

extended the deadlines for the parties to review and exchange positions as to privilege assertions 

with respect to most of the Seized Materials as set forth in the Amended Plan, see ECF 112. The 

Amended Plan did not alter the original Plan’s deadlines for reviewing and exchanging positions 

as to privilege assertions with respect to the Filter Materials.

III. ADMINISTRATIVE MATTERS

A. Staffing, Compensation, and Expenses. The undersigned is today separately 

submitting a proposal for the Court’s approval pursuant to Paragraph 15 of the Appointing 

Order.

B. Interim Reports and Adjustments to Prior Orders. In the original Appointing 

Order, the Court directed that “the Special Master shall submit interim reports and

recommendations as appropriate. Upon receipt and resolution of any interim reports and

recommendations, the Court will consider prompt adjustments to the Court’s orders as

necessary.” Appointing Order ¶ 6. However, the Court later struck that language as part of its 

order implementing an unrelated ruling by the Eleventh Circuit. As the language quoted above as 

to interim reports and adjustments to prior orders is consistent with the Eleventh Circuit’s ruling 

and the efficient administration of the Appointing Order as amended, the undersigned 

respectfully recommends that the Court issue an order reinstating that language.

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This Interim Report and Recommendation shall be filed on the docket and deemed served 

on each party today. The parties may file objections to, or motions to adopt or modify, the 

foregoing report and recommendation by October 2, 2022. Failure to timely object shall result in 

waiver of the objection. See Appointing Order, ¶ 11; Fed. R. Civ. P. 53(f). 

Dated: Brooklyn, New York /s/ Raymond J. Dearie 

September 27, 2022 RAYMOND J. DEARIE

 United States District Judge

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