UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

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DONALD J. TRUMP,

Plaintiff,

 

- against -

No. 22-81294-CIV-CANNON

UNITED STATES OF AMERICA,

Defendant.

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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. 102 and 111], 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 process. To preserve the 

confidentiality of non-public information and protect the special-master-review process, the 

Court enters this Judicial Protective Order. 

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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 staff, 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 Special Master with the names and job titles of any

staff who Plaintiff’s Counsel propose to review Seized Materials 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 Exhibit A.

1

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 

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

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

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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.

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 

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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 

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

September 23, 2022 RAYMOND J. DEARIE

United States District Judge

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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

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