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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK

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DONALD J. TRUMP,

Plaintiff,

-againstUNITED STATES OF AMERICA,

Defendant.

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22-CV-81294(AMC)

United States Courthouse

Brooklyn, New York

Tuesday, September 20, 2022

2:00 p.m.

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TRANSCRIPT OF CIVIL CAUSE FOR PREMOTION CONFERENCE

BEFORE THE HONORABLE RAYMOND J. DEARIE

SPECIAL MASTER

A P P E A R A N C E S:

For the Plaintiff: IFRAH, PLLC

Attorneys for the Plaintiff -

Donald J. Trump

1717 Pennsylvania Avenue, N.W.

Suite 650

Washington, DC 20006

BY: JAMES M. TRUSTY, ESQ.

CHRIS KISE & ASSOCIATES, P.A.

Attorneys for the Plaintiff -

Donald J. Trump

201 East Park Avenue

Suite 5th Floor

Tallahassee, Florida 32301

BY: CHRISTOPHER M. KISE, ESQ.

LINDSEY HALLIGAN, ESQ.

Attorney for the Plaintiff -

Donald J. Trump

511 S.E. 5th Avenue

Suite 1008

Fort Lauderdale, Florida 33301

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A P P E A R A N C E S: (Continued.)

SILVERMAN, THOMPSON, SLUTKIN & WHITE, LLC

Attorneys for the Plaintiff -

Donald J. Trump

400 East Pratt Street

Suite 900

Baltimore, Maryland 21230

BY: M. EVAN CORCORAN, ESQ.

For the Defendant: UNITED STATES DEPARTMENT OF JUSTICE

NATIONAL SECURITY DIVISION

For the Defendant -

United States of America

950 Pennsylvania Avenue, S.W.

Washington, DC 20530

BY: JAY I. BRATT, ESQ.

JULIE A. EDELSTEIN, ESQ.

STEVE MARZEN, ESQ.

BENJAMIN HAWK, ESQ.

UNITED STATES ATTORNEY'S OFFICE

SOUTHERN DISTRICT OF FLORIDA

For the Defendant -

United States of America

99 N.E. 4th Street

Miami, Florida 33132

BY: JUAN A. GONZALEZ, ESQ.

Court Reporter: Anthony D. Frisolone, FAPR, RDR, CRR, CRI

Official Court Reporter

Telephone: (718) 613-2487

Facsimile: (718) 613-2694

E-mail: Anthony_Frisolone@nyed.uscourts.gov

Proceedings recorded by computerized stenography.

Transcript produced by Computer-aided Transcription.

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(In open court.)

THE COURT: Good afternoon, folks, please be

seated.

COURTROOM DEPUTY: Good afternoon this is a

meeting with the Special Master in the matter of Donald

Trump versus United States of America.

Counsel, state your appearances for the record

starting with the plaintiff.

MR. TRUSTY: Good afternoon, your Honor. Jim

Trusty on behalf of the plaintiff. I'm joined by Chris

Kise, Lindsey Halligan and Evan Corcoran.

Pleasure to see you, Judge.

THE COURT: Thank you and good afternoon.

Welcome.

MR. BRATT: Jay Bratt, Tony Gonzalez from the

Southern District of Florida. Julie Edelstein from the

Department of Justice. Steve Marzen from Department of

Justice and Ben Hawk from the Department of Justice.

THE COURT: Welcome, all. I realize I've dragged

all to Brooklyn, New York albeit on a beautiful day. But

I'll try, as we go forward here, to keep this kind of thing

at a minimum as best we can.

Judge Cannon, as you all know, has asked me to

assist you all and to assist her in evaluating certain

claims. I'm going to do the best I can with the time

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available to us.

As you know, we have little time to complete the

tasks assigned to the Court. I have presented to you

yesterday a draft schedule. I've gotten your comments and I

understand there's some stated concerns about the time

allocations. I'm happy to hear you on that. Shortly after

we conclude here today, I will issue a scheduling order and

provide Judge Cannon with a copy of it as well.

I think, as a preliminary matter, I just want to

make sure I have a full understanding of what really is in

dispute. She's asked me to verify the accuracy of the

detailed property inventory; address the classification

status of the seized documents; ultimately address disputes

regarding privilege; categorization of seized documents

under the Presidential Records Act; and she's also asked me

to assess the full Rule 41 motion for return of the property

and I fully understand that motion has not yet been made.

I follow directions. I do what I'm told. We

won't be in a position to, I appreciate intelligently

address any such a claim until the first three issues that I

just noted are resolved. We note the subset of materials

that the plaintiff may have a possessive interest in.

We're going to proceed with what I call

"responsible dispatch." I'm not going to hurry but we have

a lot to do and a relatively short period of time. I'm told

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there are some 11,000 documents in play. I have no idea

what that means in terms of my workload because until I hear

from plaintiff's counsel and I'm able to evaluate the number

of challenges, claims of privilege, et cetera. Not until

then will I know fully the full range of my responsibility.

I just want to say at the outset that this is not

a criminal case. This is a civil matter brought by the

plaintiff which means, of course, the plaintiff has the

burden in the first instance of establishing his right to

relief. I realize there may be all sorts of litigation

strategies in play and I understand and respect that but

certainly can't let litigation strategy dictate my

resolution and recommendation to Judge Cannon on the

viability of any claim of privilege. I just want that to be

understood.

I'm faced with some discrete number of legal

judgments and I will endeavor to make responsibly and in due

course and follow that my recommendation to Judge Cannon

who, of course, we will describe those disputed issues of

fact.

Now, let me turn shortly, briefly, to the greatest

categories that we have.

The first being, of course, verification of the

detailed property inventory. I just want to make sure. I

haven't been able to study the file, it seems to grow by

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leaps and bounds almost by day. I've gotten familiar with

the various filings. So I have to ask: Is there a real

dispute about the property inventory?

MR. TRUSTY: Your Honor, should I address the

Court sitting down?

THE COURT: Where ever you're more comfortable

given the microphone.

MR. TRUSTY: I'm Pavlovian. I'm used to standing

up. I can try and sit here and address the Court and keep

the microphone in play.

THE COURT: I understand.

MR. TRUSTY: Judge, first of all, I completely

appreciate your preliminary comments and share that faith in

process in terms of your involvement and following quite

rigidly, I suppose, the directives of the District Court in

Florida.

On that first component, from the, again, this was

from looking at the draft plan that was submitted yesterday

or distributed yesterday, I actually think that in some ways

this issue is probably better a little deeper into the

process and I will explain why in a second. This particular

issue is not at all about strategy but what the Court is

anticipating is the plaintiff identifying, essentially,

shortcomings in the inventory ether by way of either items

that were not actually found at the locations alleged or

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mislabeled within the inventory. That actually is going to

require a full inspection of 11,000-plus items. And I will

tell the Court we're not the beneficiary from the

plaintiff's side of having some preexisting detailed

audit/inventory of our own which, again, the Court might not

be aware of that.

So we're not in a position where we're starting

with a list of 11,000. What we're starting with are the

Government's two inventories that we received. The first

one that Judge Cannon found to be insufficient under

Rule 41. But interestingly, the first one actually had a

few specifics it would say, "Pardon Package," for instance.

But it was identifying at least some of the documents. The

second one literally takes every document and says

"U.S. Government record" as the description. So we are -- I

would just submit to the Court starting from scratch.

Now, it go to the heart of your Honor's question,

I'm not -- I can't at this point make a full-blown

representation that we're sure there's nothing that is at

issue, but I think that we would all probably be well served

economically or efficiently by letting us have the time to

look at all the documents maybe electronically at first and

circle back to the Court.

I don't expect that there's going to be 11,000

instances that are at issue. There may be a handful or

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none, I don't know yet but we can do that expeditiously. I

just don't think that that should necessarily be the first

deadline in play.

THE COURT: So the answer to my question is you

don't know whether there is going to be a real dispute on

the inventory.

MR. TRUSTY: That's fair.

THE COURT: All right. Let me move on.

How quickly can you get these documents in digital

format and provide it to counsel?

MR. BRATT: Your Honor, I'm going have

Ms. Edelstein handle the questions.

THE COURT: Sure.

MS. EDELSTEIN: Good afternoon, your Honor.

THE COURT: If you're comfortable feel free to

remove your mask.

MS. EDELSTEIN: Thank you, your Honor.

As was conveyed in the letter that we filed

yesterday, the documents that are not yet in digital form.

This afternoon, we provided to the plaintiff's counsel a

list of five government-approved vendors. Once plaintiff's

counsel selects one, which we hope would be today, we would

be in a position to provide the documents to that vendor as

soon as tomorrow. So we would be hopeful that by Friday or

the latest Monday that plaintiff's counsel would have all

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the documents in digital form.

THE COURT: Any reason why we can't agree on one

of those vendors?

MR. TRUSTY: I think we can agree to move very

quickly but it's a little hard to get an e-mail right before

the hearing and then know that we've already finished our

shopping of who would be the right vendor. We can certainly

jump on it quickly and try to get the vendor selected and

throw it back to the Government to do the download of the

data or begin the rolling download of the data.

THE COURT: You're not familiar with the vendors?

MR. TRUSTY: Some of my co-counsel are familiar

but, again, we would want to have an opportunity to quickly,

you know, review each one. I think if we had till Friday to

at least pick a vendor that's, you know, and we would do

everything we can to pick a vendor tomorrow or Thursday.

THE COURT: Let's do it tomorrow. Okay. You'll

have Bates Numbers on these documents.

MS. EDELSTEIN: Yes, your Honor we'll request that

with the vendors.

THE COURT: Will they be correlated to the

inventory in any way?

MS. EDELSTEIN: We will figure out the best way to

to that but we could do expect we will Bates Number them and

we can correlate them to the inventory but that may just

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take a little bit more time on our end.

THE COURT: And will it be searchable format.

MS. EDELSTEIN: Yes, your Honor.

THE COURT: Okay. And I take it we'll get one

master list?

MS. EDELSTEIN: We will we intend to provide two

lists, one for the documents that were not identified by the

filter team as potentially privileged, and the potentially

privileged documents will be handled separately.

THE COURT: Understood. Okay.

Now, as far as the inventory itself is

concerned -- well, I think you answered the question

already. You can't tell me the answer. You can't tell me

the answer until we get the documents, all right. Fair.

So tell me, I don't know who to address,

Mr. Bratt.

I guess in the absence of relief from the Circuit,

you say you ever find a way to move forward, could you give

me some indication there what we're going to do.

MR. BRATT: Yes. Again, I will defer to

Ms. Edelstein who has had more conversations than me with

the affected parties in the case.

MS. EDELSTEIN: Yes, your Honor.

And, you know, it depends on what the

Eleventh Circuit rules. But should the Eleventh Circuit

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deny our stay, most likely we will be in a position to

consider our other appellate options at that point, and I

don't know that we're going to be able to provide the

documents on the timeframe that your Honor has requested

with respect to the classified documents only, of course.

THE COURT: I understand.

Let's get to the, if I may, the Government, of

course, wants the classified documents off the table for the

moment at least and I understand that. We're dealing with

presumably highly sensitive information. If I'm going to

verify the classification, what am I looking at? Is there a

claim that the document is classified that should not have

been classified? Is that in play before me as a special

master? Is there a claim that something was labeled

purposefully classified that isn't? What exactly is the

nature of it?

The reason I ask is if the Government essentially

gives me prima facie evidence that these are classified

documents and you, for whatever reason, decide not to

advance any claims claim of declassification which I

understand is your prerogative, I'm left with a prima facie

case of classified documents. And as far as I'm concerned,

that's the end it.

Would you then maintain that notwithstanding

they're being classified documents that you might have a

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privilege or a claim under the Records Act?

MR. TRUSTY: Your Honor, there's a lot of layers

to that question. I'll try my best to answer.

Can I take my mask off?

THE COURT: Sure.

MR. TRUSTY: First of all, yes. I mean, I think

we've telegraphed in our pleadings so far without getting to

the point of a Rule 41 that the Presidential Records Act

does supersede traditional classification concerns. It

breaks down the universe into presidential and personal

records. And in the case of someone who has been President

of the United States, they have unfettered access along with

unfettered declassification authority.

So we do think that this exercise of creating the

buckets that we've all been anticipating and the Court

anticipates makes some sense independent of whether or not

there's an ultimate concession or belief by the Court at

least that the prima facie case is made.

But the starting point is the baby steps, your

Honor. The first thing is we've never had access to these

documents so we need access we'll be asking --

THE COURT: I understand that. My question

assumed that you didn't have access. My question simply

was, if they are prima facie on their face classified by the

Executive, but is it of the Court, without any evidence to

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the contrary, to conclude that they're anything but at least

prima facie.

MR. TRUSTY: Your Honor, that's the right paradigm

in terms of without evidence to the contrary. The point is,

from our perspective, is it's premature. What we're going

to be determining through this process of actually examining

documents and sifting through and creating and narrowing

disputes before you as the special master. At the same

time, we'll be developing or not theories for why or why not

a Rule 41(g) motion should be filed. If a Rule 41(g) motion

is filed, it relies on things like the Presidential Records

Act or general warrant allegation in violation of the

Particularity Clause of the Fourth Amendment those would be

independent.

If there is an added component to that motion that

says, these are effectively declassified documents then, at

that point, it makes sense to kind of follow what I think

the Court was anticipating in the draft plan which is

providing evidence so it's not just a he said-she said of

prima facie evidence.

So my point is, our only concern in terms of what

the Court has in that plan is that it's going a little

beyond what Judge Cannon contemplated in the first instance.

It's not that your plan doesn't make sense eventually if a

Rule 41(g) claim is brought that raises the declassification

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issue, we just don't think we can say it's fully before the

Court until we've had an opportunity to examine all of the

documents and decide whether or not a pleading under Rule

41(g) is appropriate.

THE COURT: I was taken aback by your comment that

I'm going beyond what Judge Cannon instructed me to do. I

looked at her order. On the second page, she says in plain

language, as plain as can be, evaluating claims for return

of property under Rule 41(g) of the Federal Rules of

Criminal Procedure. I think I'm doing what I'm told.

MR. TRUSTY: I don't dispute that at all, Judge.

All I'm saying is the claim under §41(g) is not here yet.

So we're not in the position without having seen the

physical evidence, and without having a chance to fully

explore what these documents purport to be to tell the Court

in good faith that I know that I have an argument to be made

about declassification.

So, again, I think we're --

THE COURT: Well, you did bring the lawsuit and

make that claim.

MR. TRUSTY: Well, we've teed up the issue for

resolution by saying, we have he concerns about whether or

not the Government ignored, again, we're remembering the

context of a §41(g) being roughly parallel to a Franks

Hearing or a motion to suppress a search warrant. What

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we've done is we've raised the issue. We have not been in a

position, nor should we be at this juncture, to fully

disclose a substantive defense relating to declassification

until we see the documents and have an opportunity to

explore our options under a filing under §41(g).

So, in a sense, I may have talked past the Court

unintentionally, I apologize for that. But we agree that

you're in a position to evaluate the claims and make reports

and recommendations for §41(g) litigation. All I'm

suggesting is, as much as we want to have clarification

today, we have to take some baby steps to get to the point

where we can commit to that as a matter of presenting

evidence to you in support of a §41(g). I can't do that

without -- it's not about being kind of gamesman-like, I

just can't do that without seeing the actual documents.

THE COURT: You wouldn't do that.

MR. TRUSTY: I would not. And, you know, I

haven't been before your Honor but I can tell you there's a

slew of federal judges that would agree with me on that. I

swear to you, your Honor.

THE COURT: I take your word for it.

Okay. So, all right, I think I've probably said

all I'm going to say. But getting back to the production of

the documents which is key because it seems to me, in terms

of a realistic scheduling order, I need that in place before

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I can impose anything on the litigants.

You disagree?

MS. EDELSTEIN: No, I completely agree, your

Honor. And the Government thinks that the deadlines you

posed in this draft case management plan are very realistic.

The Government thinks that it's just of a matter of

potentially moving them back by a day or two to allow the

digital production of the records.

THE COURT: Okay.

Now, Judge Cannon allows me from time to time as

necessary to communicate with the parties ex parte. It's

not something we judges are used to doing. If it became

necessary to do that, would you advise my clerk before the

end of this session who it is in your respective camps that

I should be reaching out to. All right?

I think I've sort of touched on the areas of

concern. I'm going to give counsel an opportunity to weigh

in. And as I said, at some point I will issue a final

scheduling order.

Sir.

MR. TRUSTY: Thank you, Judge.

Your Honor, our original plans in terms of

submitting a proposed agenda to the Court obviously changed,

or at least I can tell you they changed, when we received

the draft plan from the Court. Despite the optimism

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expressed from the Government that everything's fine within

a day or two, some components are just not feasible even

under their own scenario of getting a third-party contractor

and using relatively and doing a rolling disclosure. The

reality is I think some of the deadlines included the

Government giving us electronic versions of all the

documents short of the marked ones by Thursday, and our

responding to the Court on Thursday whether or not any of

these fell afoul from the inventory list.

So, you know, we've addressed that separately as

something that I think it would probably be most efficient

to let that simmer a little bit because it could resolve a

lot of it on its own, if not all. And so, and the

compression of the dates, again, I appreciate the spirit of

the Court's draft. Number one, it's a draft. And number

two, it's trying to make it clear to the parties that we

want this train to move on time. The way it's written now

essentially compresses everything into a three-week process.

And, you know, it's not to be in favor of delay, we want

resolution on these things, too.

THE COURT: You're a week off in your calculation.

MR. TRUSTY: Okay. Four weeks then? Sorry.

THE COURT: You're a week off in your calculation.

MR. TRUSTY: I think the September 22nd part was

right. And the Court also said that at the end of the draft

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plan that we should give the Court our concerns, objections,

whatever, proposed modifications by the 25th if I remember

off the top of my head. We're happy to do that, so I don't

want to suggest to the Court that we might not have a little

bit more between now and the 25th because we're really just

kind of digesting this overnight.

THE COURT: That's why I gave you the 25th.

MR. TRUSTY: I appreciate that. We'll make that

deadline, that's not a problem. What I would just suggest

to the Court is that we do have concerns enough about the

speed at which, and it's not about lack of good faith by the

Government or by us, but I think that for 11,000 items that

can translate in some ways when you talk to these vendors

to, I think, 220 man hours of review. Now, hopefully

because a lot of these items might be photographs or might

be articles of clothing or golf shirts, that that part will

accelerate our average. But I think that, to be fully

candid with the Court, that the vendor process and the

rolling review and our review is not something that lends

itself to being done in a couple of days. It's just

physically not going to work out that way. And we'll be

more specific in a more fulsome disclosure to the Court.

So we doing, I guess, quibble a little bit about

timing in terms of what the Court anticipates. And

hopefully, as the Government, you know, consults with their

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vendors, they'll get some realistic dates there in terms of

what they think a couple of days means.

Substantively, your Honor, I this I there was

really kind of two areas that we felt were going beyond the,

or potentially going beyond the limits of what Judge Cannon

set in motion. Again, there might be a little bit more that

we come up with that we can talk about before Sunday, I

think it is, the 25th. But in the short run, we just wanted

to flag in our letter and then flag again today that we have

the concerns that we've already talked about basically about

declassification defense and when and how that should be

borne out if it's going to be, meaning, that we shouldn't be

in a position to have to disclose declarations, witness

statements, whatever it might be, to substantiate that until

a Rule 41(g) is filed.

THE COURT: I don't disagree with you. As I said

a moment ago, I guess my view of it is you can't have your

cake and eat it.

MR. TRUSTY: Sure. Understood. And, again, but I

just want the Court to know our concern there is that we

shouldn't be in a position where we're providing inherent

important components to a defense essentially at this stage.

But if we make that leap because of a §41(g) filing then so

be it. Obviously, the Court is going to want evidence, not

just pure argument.

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The second area that I wanted to or maybe one more

area after that. Within the original order of the Court,

Judge Cannon gave you as Special Master the discretion to

consult with NARA, with the National Archivist, I don't

remember the exact language, but it's essentially you have

that ability.

The Government took the opportunity in their

filing yesterday to strongly urge you to consult with NARA

as part of this process. And I would say from the

plaintiff's perspective, we would object to that. And

it's -- and I'll come back with kind of a fallback position

to make it a little easier on the Court. But we have an

objection. NARA essentially is a potential fact witness;

they are an interested party. In fact, from even recent

history, it's clear that this entity and the archivist

himself or herself in recent history have been very

politicized. Right now, it's the national archives people

that put a warning label on the U.S. Constitution because

they're concerned it will trigger people. It's the

archivist who let Sandy Berger into her personal office to

access important documents relating to 9/11 which he then

stuffed down his pants before his misdemeanor plea a few

months later.

So this is a group that has shown that even in

the, you know, in the public setting that they're highly

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politicized. We think their conduct in this case is

politicized as well. And so, it's an odd scenario to think

that a special master, particularly, a special master with

your Honor's background would have the need to get

Presidential Records Act guidance, essentially, from a group

like NARA. And I would just submit to the Court that, you

know, the flipside would be a little strange. Like, if we

said, your Honor, we have an expert on declassification and

we'd love for you to just talk to him or her ex parte

whenever you need to. I think the Court would properly

hesitate, like, wait a minute, am I getting into essentially

interested parties, fact witnesses, solicited experts,

whatever.

So I guess our concern there is broad and sincere.

If the Court gets to a point where your Honor, I'm sorry,

Special Master, as special master decides that you want to

take advantage of that discretion. We're not quibbling over

the fact that she gave you the discretion, we'd at least

like the Court to consider having us heard, have an

opportunity to address in some perhaps elliptical way what

it is that you want from NARA and for us to weigh in. But

we think the Court should err on the side of declining that

invitation that the Government keeps putting out there

because we think it's a political and partisan organization.

THE COURT: Well, I think you're painting with a

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rather broad brush to be fair to the folks at NARA. But I

don't disagree with you. I mean, at the moment, I can't

identify a need for me to speak to them. On the other hand,

if I do identify a need to speak to them, you'll be notified

and be given an opportunity to speak. I understand your

concerns.

MR. TRUSTY: Thank you, Judge.

THE COURT: Yes, sir.

MR. TRUSTY: I have one other area just to raise

and then obviously respond to any questions the Court still

has for the plaintiff.

We're not at all conceding classification.

Obviously, you're aware of that from what's got us to that

point for these hundred documents. But it does seem to make

practical sense because the Government is obviously still

believing that these are classified documents and that that

restricts access. To find a way to have expedited clearance

for more folks on my team. I actually have TS clearance

from a recent matter in the Eastern District of Virginia, so

I'm good for a few years. But it's a strange scenario

where, again, in the vacuum of not having final decisions

about classification, the Government is going to err on the

side of saying, we've got to treat it that way, we've got to

restrict access, we can't let Mr. Trusty even talk to his

fellow attorneys about what he sees. And I'm assuming the

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Court's got more clearance than has ever been created on

Earth from your background as a Judge on the FISA Court, so

I don't think it's a problem for the Court. But we would

like to see if the Court would be willing to essentially

exhort DOJ to move expeditiously on additional clearances

submitted to them. Again, just to kind of keep them

satisfied and allows us to have more access than just one

person. Usually, when you have this conversation with DOJ

or with U.S. attorneys they say, well, that's JMD, that's

Justice Management Division, they're totally different.

Yeah, they are. They're not physically sitting in the same

office but they're part of Justice. In a case like this

where all hands want to move expeditiously, we would just

appreciate some help from the Court kind of pushing that

along where we might be able to get people cleared in a way

where it doesn't slow anything down and doesn't

unnecessarily hamstring us if we review these documents.

THE COURT: Frankly, the thought occurred to me

when it was first drafted. Let's not belittle the fact that

we are dealing with at least potentially legitimately

classified information. The Government has a very strong

obligation, as all of us, to see it to that that information

doesn't get in the wrong hands. It's not just a matter, it

seems to me, of being cleared. It is a matter of need to

know. And if you need to know, you will know. That's the

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way I see it. If I can make my judgments without -- I don't

want to see the material -- it's presumably sensitive

material. If I can make my recommendation to Judge Cannon,

right or wrong, without exposing myself or to you to that

material, I will do it. On the other hand, if I can't, we

have to take another alternative.

MR. TRUSTY: Understood.

THE COURT: I take it very seriously on both sides

of the question.

All right. You completed your comments?

MR. TRUSTY: I think so. Thank you, Judge.

THE COURT: I appreciate them very much.

All right. On Uncle Sam's side. Mr. Bratt, who

is going to be your spokesperson for spokespeople.

MR. BRATT: So for purposes of the Court's contact

with the Government, I and Ms. Edelstein are the primary

contacts.

THE COURT: Okay.

MR. BRATT: One thing I'd like to clarify just in

response to something Mr. Trusty said with respect to the

vendors. Our understanding under the Judge Cannon 's order

is that they are responsible for the expenses of this

process. So we've given them vendors that are approved for

us to work with on government systems. We gave them until

tomorrow to choose an vendor. They also need to finalize

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the contract, the engagement, and payment. And we will then

after that expeditiously deliver the documents to be scanned

and Bates-stamped.

THE COURT: All right. I assume, Mr. Trusty, that

you and your colleagues will act in good faith and in your

obligations to me and to your client.

MR. TRUSTY: Your Honor, we absolutely will always

act in good faith. I would just say, having five vendors

thrown at us today with us paying for them, we have to at

last be able to show our client and ourselves what the

different numbers look like to get, you know, essentially

estimates or engagements from them. I would at least ask

till Friday. That's not asking --

THE COURT: You got it. Friday it is.

MR. TRUSTY: Thanks, Judge.

THE COURT: Anything else from the Government?

MS. EDELSTEIN: Your Honor, if I could respond to

a couple other points made by Mr. Trusty.

THE COURT: By all means.

MS. EDELSTEIN: And with respect to the timeline,

even if the vendor is selected on Friday, I think we'll be

in a position early next week to provide the documents over

to plaintiff's counsel and that should only necessitate the

moving of the proposed deadlines in your scheduling order by

a couple days.

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THE COURT: You'll keep me informed.

MS. EDELSTEIN: Yes, your Honor, we will.

With respect to NARA. The appointment order, of

course, does give you discretion to consult with them. And

I would just point out that these documents are supposed to

be NARA's custody. And if they had not be stored in an

improper place, they would be in the custody of NARA now.

And we will, of course, defer to you, your Honor, as to how

helpful you find it to consult with NARA if you want to do

so. But I would point out that some of the documents would

require a call. For instance, if there is a newspaper

article that has the former president's handwriting on it,

does that make it a presidential record? And NARA, with

their expertise, is in the best position to make these kind

of determinations and may be able to assist you.

THE COURT: I won't hesitate if I think I need

their help.

MS. EDELSTEIN: I understand, your Honor.

THE COURT: I'm not going in with any preconceived

notion that I need a tutorial from NARA, that's all.

MS. EDELSTEIN: Understood.

We also want to make clear the Government's

position that the classification status of the documents

isn't ultimately for the Judicial Branch to decide. The

classification of documents under prevailing case law

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including the Supreme Court's ruling in the Department of

Navy v. Egan makes very clear that it's an Executive Branch

determination whether to classify document and how to

control access to classified documents.

So while the Government has no objection to you

ordering to provide plaintiff's counsel to provide a

declaration along the lines that you have suggested with

respect to the declassification issue, the Government wants

to make clear that under the law we believe it is the

current Executive Branch's decision only, ultimately, as to

whether the documents are classified.

THE COURT: I understand that's your position.

MS. EDELSTEIN: And finally, we would like to

reiterate the point that your Honor made that there must be

a need to know to share classified information. And in

addition to that, even if Mr. Trusty has a top secret

clearance, that clearance alone without a reasons should he

have a need to know would not be sufficient to see number of

the documents at issue in this case. Some of the documents

are so sensitive that even members of the team that is

investigating possible offenses here have not yet been

provided the clearances to see these documents.

So we just want to make your Honor aware of the

very highly sensitive documents involved in this case.

THE COURT: I appreciate that.

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MR. TRUSTY: Your Honor, two very quick things in

response.

THE COURT: Yes, Mr. Trusty.

MR. TRUSTY: First, it's kind of astounding to

hear the Government say that the President's lawyers don't

have a need to know. I mean, I know we're not sorting

through the final classification issues her. It's kind of

an amazing juncture to be dismissive of even one attorney

having access to the documents that form the justification

for their raid. But I will also want to go back --

THE COURT: I didn't hear you say that. If you

have a need to know for the appropriate resolution of this

issue.

MR. TRUSTY: I believe we have a need to know,

absolutely. I don't know how we can fully address the

issues that might come with a Rule 41 without having some

access under all sorts protective measures but some access.

I will say I want to finish with one other point which is a

letter from the National Archivist on March 30th of 2017 to

Members of the Committee on Homeland Security and Government

Affairs. I just think this line is perfectly appropriate

point in response to what we just heard about consulting

NARA. The answer from the archivist to a question about

this was about President Trump's tweets as presidential

records was: No, under the PRA, Presidential Records Act,

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records management authority is vested in the President and

NARA does not make determinations with respect to whether

something is or is not a presidential record.

I mean again, I made my points about NARA but

there they are affirmatively saying that's not our game to

make these classifications. So, again, you will see more

writing from us on this issue because we think it's an

overarching issue that essentially negates the issue of

classification.

THE COURT: We're all in agreement then. NARA

doesn't it, I don't. Judge Cannon does. And with that,

we'll be, once we get the schedule in place, I will include

in there another conference call, a progress conference, and

I hope with an emphasis on the word "progress." I'll call

it a "progress conference." Hopefully, we can do it

electronically so we don't have to bring everybody to

Brooklyn, not that I know most of you are just dying to be

in Brooklyn. So we'll be in touch with that once we get the

schedule in place.

Anything else?

MR. TRUSTY: Not for plaintiff, Judge.

THE COURT: I have a hand in the background.

MR. HAWK: Yes, your Honor. Benjamin Hawk on

behalf of United States. For the record, I am

representative of the Government's filter team. I did want

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to address several things, your Honor.

First, the filter team's materials which consist

of approximately 520 pages. Pursuant to Judge Cannon's

order, those have been provided to plaintiff's counsel as of

Friday. I have a courtesy copy here for your Honor both in

paper and electronic format if I can provide that to the

Court.

THE COURT: Please.

MR. HAWK: And to the clerk.

THE COURT: Thank you.

MR. HAWK: May I approach?

THE COURT: We are making progress.

Okay. Anything else?

MR. HAWK: Yes, your Honor. I did want to point

out that your Honor asked for with respect to the inventory

and the log and the spreadsheet. I just wanted to clarify

that the filter materials -- the filter team has already

separated those out from the seized materials and we have a

separate spreadsheet that we can provide to plaintiff's

counsel to take care of those documents with respect to any

privilege claims that plaintiff's counsel may have.

THE COURT: Much appreciated. I assumed you would

set it up that way and I appreciate your offer as I'm sure

does Mr. Trusty and his colleagues.

Anything else?

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MR. HAWK: That's it, your Honor. Thank you.

THE COURT: Thank you, folks. I appreciate your

time.

MS. EDELSTEIN: One more quick thing.

With respect to the affidavit that the Court

contemplates the Government official providing tomorrow with

respect to the inventory. Would it be okay in the public

version to redact the agent's name signing that declaration?

THE COURT: Yes.

MS. EDELSTEIN: Thank you.

THE COURT: For the time being, sure. Thank you.

(WHEREUPON, this matter was adjourned.)

* * *

CERTIFICATE OF REPORTER

I certify that the foregoing is a correct transcript of the

record of proceedings in the above-entitled matter.

________________________________________

Anthony D. Frisolone, FAPR, RDR, CRR, CRI

Official Court Reporter

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1008 [1] - 1:23

11,000 [4] - 5:1, 7:8, 7:24, 18:12

11,000-plus [1] - 7:2

1717 [1] - 1:15

2

20 [1] - 1:7

20006 [1] - 1:16

201 [1] - 1:19

2017 [1] - 28:19

2022 [1] - 1:7

20530 [1] - 2:9

21230 [1] - 2:5

22-CV-81294(AMC [1] - 1:3

220 [1] - 18:14

22nd [1] - 17:24

25th [4] - 18:2, 18:5, 18:7, 19:8

2:00 [1] - 1:8

3

30th [1] - 28:19

32301 [1] - 1:20

33132 [1] - 2:14

33301 [1] - 1:24

4

400 [1] - 2:4

41 [4] - 4:16, 7:11, 12:8, 28:16

41(g [6] - 13:10, 13:25, 14:4, 14:9, 19:15

4th [1] - 2:14

5

511 [1] - 1:23

520 [1] - 30:3

5th [2] - 1:19, 1:23

6

613-2487 [1] - 2:17

613-2694 [1] - 2:17

650 [1] - 1:15

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718 [2] - 2:17, 2:17

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9/11 [1] - 20:21

900 [1] - 2:4

950 [1] - 2:8

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aback [1] - 14:5

ability [1] - 20:6

able [6] - 5:3, 5:25, 11:3, 23:15, 25:10,

26:15

above-entitled [1] - 31:18

absence [1] - 10:17

absolutely [2] - 25:7, 28:15

accelerate [1] - 18:17

access [12] - 12:12, 12:20, 12:21, 12:23,

20:21, 22:17, 22:24, 23:7, 27:4, 28:9,

28:17

accuracy [1] - 4:11

Act [1] - 12:1

act [2] - 25:5, 25:8

actual [1] - 15:15

added [1] - 13:15

addition [1] - 27:16

additional [1] - 23:5

address [9] - 4:12, 4:13, 4:20, 6:4, 6:9,

10:15, 21:20, 28:15, 30:1

addressed [1] - 17:10

adjourned [1] - 31:12

advance [1] - 11:20

advantage [1] - 21:17

advise [1] - 16:13

Affairs [1] - 28:21

affected [1] - 10:22

affidavit [1] - 31:5

affirmatively[1] - 29:5

afoul [1] - 17:9

afternoon [6] - 3:2, 3:4, 3:9, 3:13, 8:14,

8:20

agenda [1] - 16:23

agent's [1] - 31:8

ago [1] - 19:17

agree [5] - 9:2, 9:4, 15:7, 15:19, 16:3

agreement [1] - 29:10

aided [1] - 2:19

albeit [1] - 3:20

allegation [1] - 13:12

alleged [1] - 6:25

allocations [1] - 4:6

allow [1] - 16:7

allows [2] - 16:10, 23:7

almost [1] - 6:1

alone [1] - 27:17

alternative [1] - 24:6

amazing [1] - 28:8

America [3] - 2:8, 2:13, 3:6

AMERICA[1] - 1:8

answer[5] - 8:4, 10:13, 10:14, 12:3,

28:23

answered [1] - 10:12

anticipates [2] - 12:16, 18:24

anticipating [3] - 6:23, 12:15, 13:18

apologize [1] - 15:7

appearances [1] - 3:7

appellate [1] - 11:2

appointment [1] - 26:3

appreciate [9] - 4:19, 6:13, 17:14, 18:8,

23:14, 24:12, 27:25, 30:23, 31:2

appreciated [1] - 30:22

Anthony D. Frisolone, FAPR, RDR, CRR, CRI, CSR

Official Court Reporter

(1008 - broad) Page 1

approach [1] - 30:11

appropriate [3] - 14:4, 28:12, 28:21

approved [2] - 8:21, 24:23

Archivist[2] - 20:4, 28:19

archivist [3] - 20:15, 20:20, 28:23

area [3] - 20:1, 20:2, 22:9

areas [2] - 16:16, 19:4

argument [2] - 14:16, 19:25

article [1] - 26:12

articles [1] - 18:16

assess [1] - 4:16

assigned [1] - 4:3

assist [3] - 3:24, 26:15

ASSOCIATES[1] - 1:17

assume [1] - 25:4

assumed [2] - 12:23, 30:22

assuming [1] - 22:25

astounding [1] - 28:4

attorney [2] - 1:22, 28:8

ATTORNEY'S [1] - 2:12

Attorneys[2] - 1:14, 2:3

attorneys [3] - 1:18, 22:25, 23:9

audit/inventory [1] - 7:5

authority [2] - 12:13, 29:1

available [1] - 4:1

Avenue [3] - 1:15, 1:23, 2:8

average [1] - 18:17

aware [3] - 7:6, 22:13, 27:23

B

baby [2] - 12:19, 15:11

background [3] - 21:4, 23:2, 29:22

Baltimore [1] - 2:5

Bates [3] - 9:18, 9:24, 25:3

Bates-stamped [1] - 25:3

beautiful [1] - 3:20

became [1] - 16:12

BEFORE [1] - 1:11

begin [1] - 9:10

behalf [2] - 3:10, 29:24

belief [1] - 12:17

belittle [1] - 23:19

Ben [1] - 3:18

beneficiary [1] - 7:3

Benjamin [1] - 29:23

BENJAMIN [1] - 2:11

Berger[1] - 20:20

best [5] - 3:22, 3:25, 9:23, 12:3, 26:14

better[1] - 6:20

between [1] - 18:5

beyond [4] - 13:23, 14:6, 19:4, 19:5

bit [5] - 10:1, 17:12, 18:5, 18:23, 19:6

blown [1] - 7:18

borne [1] - 19:12

bounds [1] - 6:1

Branch's [1] - 27:10

Bratt [3] - 3:15, 10:16, 24:13

BRATT[6] - 2:9, 3:15, 8:11, 10:20,

24:15, 24:19

breaks [1] - 12:10

briefly [1] - 5:21

bring [2] - 14:19, 29:16

broad [2] - 21:14, 22:1

Case 9:22-cv-81294-AMC Document 147 Entered on FLSD Docket 10/13/2022 Page 32 of 38
Brooklyn [4] - 1:5, 3:20, 29:17, 29:18

brought [2] - 5:7, 13:25

brush [1] - 22:1

buckets [1] - 12:15

burden [1] - 5:9

BY [5] - 1:16, 1:20, 2:5, 2:9, 2:15

C

cake [1] - 19:18

calculation [2] - 17:21, 17:23

camps [1] - 16:14

candid [1] - 18:18

Cannon [13] - 3:23, 4:8, 5:13, 5:18, 7:10,

13:23, 14:6, 16:10, 19:5, 20:3, 24:3,

24:21, 29:11

Cannon's [1] - 30:3

care [1] - 30:20

case [11] - 5:7, 10:22, 11:22, 12:11,

12:18, 16:5, 21:1, 23:12, 26:25, 27:19,

27:24

categories [1] - 5:22

categorization [1] - 4:14

CAUSE[1] - 1:10

certain [1] - 3:24

certainly [2] - 5:12, 9:7

CERTIFICATE[1] - 31:16

certify [1] - 31:17

cetera [1] - 5:4

challenges [1] - 5:4

chance [1] - 14:14

changed [2] - 16:23, 16:24

choose [1] - 24:25

CHRIS [1] - 1:17

Chris [1] - 3:10

CHRISTOPHER [1] - 1:20

circle [1] - 7:23

Circuit [3] - 10:17, 10:25

CIVIL [1] - 1:10

civil [1] - 5:7

claim [9] - 4:20, 5:14, 11:12, 11:14,

11:20, 12:1, 13:25, 14:12, 14:20

claims [6] - 3:25, 5:4, 11:20, 14:8, 15:8,

30:21

clarification [1] - 15:10

clarify [2] - 24:19, 30:16

classification [9] - 4:12, 11:11, 12:9,

22:12, 22:22, 26:23, 26:25, 28:7, 29:9

classifications [1] - 29:6

classified [14] - 11:5, 11:8, 11:12, 11:13,

11:15, 11:18, 11:22, 11:25, 12:24, 22:16,

23:21, 27:4, 27:11, 27:15

classify [1] - 27:3

Clause [1] - 13:13

clear[5] - 17:16, 20:15, 26:22, 27:2,

27:9

clearance [5] - 22:17, 22:18, 23:1, 27:17

clearances [2] - 23:5, 27:22

cleared [2] - 23:15, 23:24

clerk [2] - 16:13, 30:9

client [2] - 25:6, 25:10

clothing [1] - 18:16

co [1] - 9:12

co-counsel [1] - 9:12

colleagues [2] - 25:5, 30:24

comfortable [2] - 6:6, 8:15

comment [1] - 14:5

comments [3] - 4:4, 6:13, 24:10

commit [1] - 15:12

Committee [1] - 28:20

communicate [1] - 16:11

complete [1] - 4:2

completed [1] - 24:10

completely [2] - 6:12, 16:3

component [2] - 6:17, 13:15

components [2] - 17:2, 19:22

compresses [1] - 17:18

compression [1] - 17:14

Computer[1] - 2:19

Computer-aided [1] - 2:19

computerized [1] - 2:19

conceding [1] - 22:12

concern [4] - 13:21, 16:17, 19:20, 21:14

concerned [3] - 10:12, 11:22, 20:19

concerns [7] - 4:5, 12:9, 14:22, 18:1,

18:10, 19:10, 22:6

concession [1] - 12:17

conclude [2] - 4:7, 13:1

conduct [1] - 21:1

conference [3] - 29:13, 29:15

CONFERENCE [1] - 1:10

consider[2] - 11:2, 21:19

consist [1] - 30:2

Constitution [1] - 20:18

consult [4] - 20:4, 20:8, 26:4, 26:9

consulting [1] - 28:22

consults [1] - 18:25

contact [1] - 24:15

contacts [1] - 24:17

contemplated [1] - 13:23

contemplates [1] - 31:6

context [1] - 14:24

Continued [1] - 2:1

contract [1] - 25:1

contractor[1] - 17:3

contrary [2] - 13:1, 13:4

control [1] - 27:4

conversation [1] - 23:8

conversations [1] - 10:21

conveyed[1] - 8:18

copy [2] - 4:8, 30:5

CORCORAN [1] - 2:5

Corcoran [1] - 3:11

correct [1] - 31:17

correlate [1] - 9:25

correlated [1] - 9:21

counsel [13] - 3:7, 5:3, 8:10, 8:20, 8:22,

8:25, 9:12, 16:17, 25:23, 27:6, 30:4,

30:20, 30:21

couple [4] - 18:20, 19:2, 25:18, 25:25

course [8] - 5:8, 5:18, 5:19, 5:23, 11:5,

11:8, 26:4, 26:8

court [1] - 3:1

Court [46] - 2:16, 2:16, 4:3, 6:5, 6:9,

6:15, 6:22, 7:3, 7:5, 7:16, 7:23, 12:15,

12:17, 12:25, 13:18, 13:22, 14:2, 14:15,

15:6, 16:23, 16:25, 17:8, 17:25, 18:1,

18:4, 18:10, 18:18, 18:22, 18:24, 19:20,

19:24, 20:2, 20:12, 21:6, 21:10, 21:15,

21:19, 21:22, 22:10, 23:2, 23:3, 23:4,

Anthony D. Frisolone, FAPR, RDR, CRR, CRI, CSR

Official Court Reporter

(Brooklyn - dispute) Page 2

23:14, 30:7, 31:5, 31:24

Court's [4] - 17:15, 23:1, 24:15, 27:1

courtesy [1] - 30:5

Courthouse [1] - 1:5

COURTROOM [1] - 3:4

created [1] - 23:1

creating [2] - 12:14, 13:7

criminal [1] - 5:7

Criminal [1] - 14:10

current [1] - 27:10

custody [2] - 26:6, 26:7

D

data [2] - 9:10

dates [2] - 17:14, 19:1

days [3] - 18:20, 19:2, 25:25

DC [2] - 1:16, 2:9

deadline [2] - 8:3, 18:9

deadlines [3] - 16:4, 17:5, 25:24

dealing [2] - 11:9, 23:20

DEARIE[1] - 1:11

decide [3] - 11:19, 14:3, 26:24

decides [1] - 21:16

decision [1] - 27:10

decisions [1] - 22:21

declaration [2] - 27:7, 31:8

declarations [1] - 19:13

declassification [8] - 11:20, 12:13,

13:25, 14:17, 15:3, 19:11, 21:8, 27:8

declassified [1] - 13:16

declining [1] - 21:22

deeper[1] - 6:20

defendant [1] - 1:9

defense [3] - 15:3, 19:11, 19:22

defer[2] - 10:20, 26:8

delay [1] - 17:19

deliver[1] - 25:2

deny [1] - 11:1

Department [1] - 27:1

Department of justice [4] - 2:6, 3:17,

3:18

DEPUTY[1] - 3:4

describe [1] - 5:19

description [1] - 7:15

despite [1] - 16:25

detailed [3] - 4:12, 5:24, 7:4

determination [1] - 27:3

determinations [2] - 26:15, 29:2

determining [1] - 13:6

developing [1] - 13:9

dictate [1] - 5:12

different [2] - 23:10, 25:11

digesting [1] - 18:6

digital [4] - 8:9, 8:19, 9:1, 16:8

directions [1] - 4:18

directives [1] - 6:15

disagree [3] - 16:2, 19:16, 22:2

disclose [2] - 15:3, 19:13

disclosure [2] - 17:4, 18:22

discrete [1] - 5:16

discretion [4] - 20:3, 21:17, 21:18, 26:4

dismissive [1] - 28:8

dispatch [1] - 4:24

dispute [4] - 4:11, 6:3, 8:5, 14:11

Case 9:22-cv-81294-AMC Document 147 Entered on FLSD Docket 10/13/2022 Page 33 of 38
disputed [1] - 5:19

disputes [2] - 4:13, 13:8

distributed [1] - 6:19

DISTRICT [3] - 1:1, 1:1, 2:12

District [3] - 3:16, 6:15, 22:19

DIVISION [1] - 2:7

Division [1] - 23:10

document [3] - 7:14, 11:12, 27:3

documents [46] - 4:13, 4:14, 5:1, 7:13,

7:22, 8:9, 8:19, 8:23, 9:1, 9:18, 10:7,

10:9, 10:14, 11:4, 11:5, 11:8, 11:19,

11:22, 11:25, 12:21, 13:7, 13:16, 14:3,

14:15, 15:4, 15:15, 15:24, 17:7, 20:21,

22:14, 22:16, 23:17, 25:2, 25:22, 26:5,

26:10, 26:23, 26:25, 27:4, 27:11, 27:19,

27:22, 27:24, 28:9, 30:20

DOJ [2] - 23:5, 23:8

DONALD [1] - 1:3

Donald [5] - 1:14, 1:18, 1:22, 2:3, 3:5

done [2] - 15:1, 18:20

down [4] - 6:5, 12:10, 20:22, 23:16

download [2] - 9:9, 9:10

draft [8] - 4:4, 6:18, 13:18, 16:5, 16:25,

17:15, 17:25

drafted [1] - 23:19

dragged [1] - 3:19

due [1] - 5:17

dying [1] - 29:17

E

e-mail [1] - 9:5

E-mail [1] - 2:18

early [1] - 25:22

Earth [1] - 23:2

easier[1] - 20:12

East [2] - 1:19, 2:4

Eastern [1] - 22:19

EASTERN[1] - 1:1

eat [1] - 19:18

economically [1] - 7:21

Edelstein [4] - 3:16, 8:12, 10:21, 24:16

EDELSTEIN [17] - 2:10, 8:14, 8:17, 9:19,

9:23, 10:3, 10:6, 10:23, 16:3, 25:17,

25:20, 26:2, 26:18, 26:21, 27:13, 31:4,

31:10

effectively [1] - 13:16

efficient [1] - 17:11

efficiently [1] - 7:21

Egan [1] - 27:2

either[1] - 6:24

electronic [2] - 17:6, 30:6

electronically [2] - 7:22, 29:16

Eleventh [2] - 10:25

elliptical [1] - 21:20

emphasis [1] - 29:14

end [4] - 10:1, 11:23, 16:14, 17:25

endeavor[1] - 5:17

engagement [1] - 25:1

engagements [1] - 25:12

entitled [1] - 31:18

entity [1] - 20:15

err[2] - 21:22, 22:22

ESQ [9] - 1:16, 1:20, 1:21, 2:5, 2:9, 2:10,

2:10, 2:11, 2:15

essentially [11] - 6:23, 11:17, 17:18,

19:22, 20:5, 20:13, 21:5, 21:11, 23:4,

25:11, 29:8

establishing [1] - 5:9

estimates [1] - 25:12

et [1] - 5:4

ether[1] - 6:24

evaluate [2] - 5:3, 15:8

evaluating [2] - 3:24, 14:8

Evan [1] - 3:11

EVAN [1] - 2:5

eventually [1] - 13:24

evidence [8] - 11:18, 12:25, 13:4, 13:19,

13:20, 14:14, 15:13, 19:24

ex [2] - 16:11, 21:9

exact [1] - 20:5

exactly [1] - 11:15

examine [1] - 14:2

examining [1] - 13:6

Executive [2] - 12:25, 27:10

Executive Branch [1] - 27:2

exercise [1] - 12:14

exhort [1] - 23:5

expect [2] - 7:24, 9:24

expedited [1] - 22:17

expeditiously [4] - 8:1, 23:5, 23:13, 25:2

expenses [1] - 24:22

expert [1] - 21:8

expertise [1] - 26:14

experts [1] - 21:12

explain [1] - 6:21

explore [2] - 14:15, 15:5

exposing [1] - 24:4

expressed [1] - 17:1

F

face [1] - 12:24

faced [1] - 5:16

facie [6] - 11:18, 11:21, 12:18, 12:24,

13:2, 13:20

Facsimile [1] - 2:17

fact [6] - 5:20, 20:13, 20:14, 21:12,

21:18, 23:19

fair[3] - 8:7, 10:14, 22:1

faith [5] - 6:13, 14:16, 18:11, 25:5, 25:8

fallback [1] - 20:11

familiar[3] - 6:1, 9:11, 9:12

far[3] - 10:11, 11:22, 12:7

favor[1] - 17:19

feasible [1] - 17:2

federal [1] - 15:19

Federal [1] - 14:9

fell [1] - 17:9

fellow [1] - 22:25

felt [1] - 19:4

few [3] - 7:12, 20:22, 22:20

figure [1] - 9:23

file [1] - 5:25

filed [4] - 8:18, 13:10, 13:11, 19:15

filing [3] - 15:5, 19:23, 20:8

filings [1] - 6:2

filter [5] - 10:8, 29:25, 30:2, 30:17

final [3] - 16:18, 22:21, 28:7

finalize [1] - 24:25

Anthony D. Frisolone, FAPR, RDR, CRR, CRI, CSR

Official Court Reporter

(disputed - HALLIGAN) Page 3

finally [1] - 27:13

fine [1] - 17:1

finish [1] - 28:18

finished [1] - 9:6

first [15] - 4:20, 5:9, 5:23, 6:12, 6:17,

7:9, 7:11, 7:22, 8:2, 12:6, 12:20, 13:23,

23:19, 28:4, 30:2

FISA [1] - 23:2

five [2] - 8:21, 25:8

flag [2] - 19:9

flipside [1] - 21:7

Floor [1] - 1:19

FLORIDA [1] - 2:12

Florida [5] - 1:20, 1:24, 2:14, 3:16, 6:16

folks [4] - 3:2, 22:1, 22:18, 31:2

follow [3] - 4:18, 5:18, 13:17

following [1] - 6:14

FOR [1] - 1:10

foregoing [1] - 31:17

form [3] - 8:19, 9:1, 28:9

format [3] - 8:10, 10:2, 30:6

former[1] - 26:12

Fort [1] - 1:24

forward [2] - 3:21, 10:18

four [1] - 17:22

Fourth Amendment[1] - 13:13

frankly [1] - 23:18

Franks [1] - 14:24

free [1] - 8:15

Friday [6] - 8:24, 9:14, 25:13, 25:14,

25:21, 30:5

full [5] - 4:10, 4:16, 5:5, 7:2, 7:18

full-blown [1] - 7:18

fully [7] - 4:17, 5:5, 14:1, 14:14, 15:2,

18:17, 28:15

fulsome [1] - 18:22

G

game [1] - 29:5

gamesman [1] - 15:14

gamesman-like [1] - 15:14

general [1] - 13:12

given [3] - 6:7, 22:5, 24:23

golf [1] - 18:16

Gonzalez [1] - 3:15

GONZALEZ [1] - 2:15

Government[23] - 7:15, 9:9, 11:7,

11:17, 14:23, 16:4, 16:6, 17:1, 17:6,

18:12, 18:25, 20:7, 21:23, 22:15, 22:22,

23:21, 24:16, 25:16, 27:5, 27:8, 28:5,

28:20, 31:6

government[2] - 8:21, 24:24

Government's [3] - 7:9, 26:22, 29:25

government-approved [1] - 8:21

greatest [1] - 5:21

group [2] - 20:24, 21:5

grow [1] - 5:25

guess [4] - 10:17, 18:23, 19:17, 21:14

guidance [1] - 21:5

H

HALLIGAN [1] - 1:21

Case 9:22-cv-81294-AMC Document 147 Entered on FLSD Docket 10/13/2022 Page 34 of 38
Halligan [1] - 3:11

hamstring [1] - 23:17

hand [3] - 22:3, 24:5, 29:22

handful [1] - 7:25

handle [1] - 8:12

handled [1] - 10:9

hands [2] - 23:13, 23:23

handwriting [1] - 26:12

happy [2] - 4:6, 18:3

hard [1] - 9:5

Hawk [2] - 3:18, 29:23

HAWK [6] - 2:11, 29:23, 30:9, 30:11,

30:14, 31:1

head [1] - 18:3

hear[4] - 4:6, 5:2, 28:5, 28:11

heard [2] - 21:19, 28:22

Hearing [1] - 14:25

hearing [1] - 9:6

heart [1] - 7:17

help [2] - 23:14, 26:17

helpful [1] - 26:9

herself [1] - 20:16

hesitate [2] - 21:11, 26:16

highly [3] - 11:10, 20:25, 27:24

himself [1] - 20:16

history [2] - 20:15, 20:16

Homeland [1] - 28:20

Honor [33] - 3:9, 6:4, 8:11, 8:14, 8:17,

9:19, 10:3, 10:23, 11:4, 12:2, 12:20, 13:3,

15:18, 15:20, 16:4, 16:22, 19:3, 21:8,

21:15, 25:7, 25:17, 26:2, 26:8, 26:18,

27:14, 27:23, 28:1, 29:23, 30:1, 30:5,

30:14, 30:15, 31:1

Honor's [2] - 7:17, 21:4

HONORABLE [1] - 1:11

hope [2] - 8:22, 29:14

hopeful [1] - 8:24

hopefully [3] - 18:14, 18:25, 29:15

hours [1] - 18:14

hundred [1] - 22:14

hurry [1] - 4:24

I

idea [1] - 5:1

identified [1] - 10:7

identify [2] - 22:3, 22:4

identifying [2] - 6:23, 7:13

IFRAH [1] - 1:13

ignored [1] - 14:23

important [2] - 19:22, 20:21

impose [1] - 16:1

improper[1] - 26:7

include [1] - 29:12

included [1] - 17:5

including [1] - 27:1

independent [2] - 12:16, 13:14

indication [1] - 10:19

information [4] - 11:10, 23:21, 23:22,

27:15

informed [1] - 26:1

inherent [1] - 19:21

inspection [1] - 7:2

instance [4] - 5:9, 7:12, 13:23, 26:11

instances [1] - 7:25

instructed [1] - 14:6

insufficient [1] - 7:10

intelligently [1] - 4:19

intend [1] - 10:6

interest [1] - 4:22

interested [2] - 20:14, 21:12

interestingly [1] - 7:11

inventories [1] - 7:9

inventory [12] - 4:12, 5:24, 6:3, 6:24,

7:1, 8:6, 9:22, 9:25, 10:11, 17:9, 30:15,

31:7

investigating [1] - 27:21

invitation [1] - 21:23

involved [1] - 27:24

involvement[1] - 6:14

issue [15] - 4:7, 6:20, 6:22, 7:20, 7:25,

14:1, 14:21, 15:1, 16:18, 27:8, 27:19,

28:13, 29:7, 29:8

issues [4] - 4:20, 5:19, 28:7, 28:16

items [4] - 6:24, 7:2, 18:12, 18:15

itself [2] - 10:11, 18:20

J

JAMES[1] - 1:16

JAY[1] - 2:9

Jay [1] - 3:15

Jim [1] - 3:9

JMD [1] - 23:9

joined [1] - 3:10

JUAN [1] - 2:15

judge [1] - 6:12

Judge [22] - 3:12, 3:23, 4:8, 5:13, 5:18,

7:10, 13:23, 14:6, 14:11, 16:10, 16:21,

19:5, 20:3, 22:7, 23:2, 24:3, 24:11, 24:21,

25:15, 29:11, 29:21, 30:3

judges [2] - 15:19, 16:12

judgments [2] - 5:17, 24:1

Judicial Branch [1] - 26:24

JULIE [1] - 2:10

Julie [1] - 3:16

jump [1] - 9:8

juncture [2] - 15:2, 28:8

Justice [2] - 23:10, 23:12

justification [1] - 28:9

K

keep [4] - 3:21, 6:9, 23:6, 26:1

keeps [1] - 21:23

key [1] - 15:24

kind [11] - 3:21, 13:17, 15:14, 18:6, 19:4,

20:11, 23:6, 23:14, 26:14, 28:4, 28:7

KISE [2] - 1:17, 1:20

Kise [1] - 3:11

L

label [1] - 20:18

labeled [1] - 11:14

lack [1] - 18:11

language [2] - 14:8, 20:5

last [1] - 25:10

latest [1] - 8:25

Anthony D. Frisolone, FAPR, RDR, CRR, CRI, CSR

Official Court Reporter

(Halligan - might) Page 4

Lauderdale [1] - 1:24

law [2] - 26:25, 27:9

lawsuit [1] - 14:19

lawyers [1] - 28:5

layers [1] - 12:2

leap [1] - 19:23

leaps [1] - 6:1

least [9] - 7:13, 9:15, 11:9, 12:18, 13:1,

16:24, 21:18, 23:20, 25:12

left [1] - 11:21

legal [1] - 5:16

legitimately [1] - 23:20

lends [1] - 18:19

letter[3] - 8:18, 19:9, 28:19

letting [1] - 7:21

likely [1] - 11:1

limits [1] - 19:5

LINDSEY [1] - 1:21

Lindsey [1] - 3:11

line [1] - 28:21

lines [1] - 27:7

list [4] - 7:8, 8:21, 10:5, 17:9

lists [1] - 10:7

literally [1] - 7:14

litigants [1] - 16:1

litigation [3] - 5:10, 5:12, 15:9

LLC [1] - 2:2

locations [1] - 6:25

log [1] - 30:16

look [2] - 7:22, 25:11

looked [1] - 14:7

looking [2] - 6:18, 11:11

love [1] - 21:9

M

mail [2] - 2:18, 9:5

maintain [1] - 11:24

man [1] - 18:14

management [2] - 16:5, 29:1

Management[1] - 23:10

March [1] - 28:19

marked [1] - 17:7

Maryland [1] - 2:5

Marzen [1] - 3:17

MARZEN [1] - 2:10

mask [2] - 8:16, 12:4

MASTER[1] - 1:11

Master[3] - 3:5, 20:3, 21:16

master[6] - 10:5, 11:14, 13:8, 21:3,

21:16

material [3] - 24:2, 24:3, 24:5

materials [4] - 4:21, 30:2, 30:17, 30:18

matter[10] - 3:5, 4:9, 5:7, 15:12, 16:6,

22:19, 23:23, 23:24, 31:12, 31:18

mean [4] - 12:6, 22:2, 28:6, 29:4

meaning [1] - 19:12

means [4] - 5:2, 5:8, 19:2, 25:19

measures [1] - 28:17

meeting [1] - 3:5

members [1] - 27:20

Members [1] - 28:20

Miami [1] - 2:14

microphone [2] - 6:7, 6:10

might [9] - 7:5, 11:25, 18:4, 18:15, 19:6,

Case 9:22-cv-81294-AMC Document 147 Entered on FLSD Docket 10/13/2022 Page 35 of 38
19:14, 23:15, 28:16

minimum [1] - 3:22

minute [1] - 21:11

misdemeanor[1] - 20:22

mislabeled [1] - 7:1

modifications [1] - 18:2

moment [3] - 11:9, 19:17, 22:2

Monday [1] - 8:25

months [1] - 20:23

most [3] - 11:1, 17:11, 29:17

motion [7] - 4:16, 4:17, 13:10, 13:15,

14:25, 19:6

move [6] - 8:8, 9:4, 10:18, 17:17, 23:5,

23:13

moving [2] - 16:7, 25:24

MS [16] - 8:14, 8:17, 9:19, 9:23, 10:3,

10:6, 10:23, 16:3, 25:17, 25:20, 26:2,

26:18, 26:21, 27:13, 31:4, 31:10

must [1] - 27:14

N

N.E [1] - 2:14

N.W [1] - 1:15

name [1] - 31:8

NARA[15] - 20:4, 20:8, 20:13, 21:6,

21:21, 22:1, 26:3, 26:7, 26:9, 26:13,

26:20, 28:23, 29:2, 29:4, 29:10

NARA's [1] - 26:6

narrowing [1] - 13:7

National [2] - 20:4, 28:19

NATIONAL[1] - 2:7

national archives [1] - 20:17

nature [1] - 11:16

Navy [1] - 27:2

necessarily [1] - 8:2

necessary [2] - 16:11, 16:13

necessitate [1] - 25:23

need [16] - 12:21, 15:25, 21:4, 21:10,

22:3, 22:4, 23:24, 23:25, 24:25, 26:16,

26:20, 27:15, 27:18, 28:6, 28:12, 28:14

negates [1] - 29:8

never[1] - 12:20

NEW [1] - 1:1

New [2] - 1:5, 3:20

newspaper[1] - 26:11

next [1] - 25:22

none [1] - 8:1

note [1] - 4:21

noted [1] - 4:21

nothing [1] - 7:19

notified [1] - 22:4

notion [1] - 26:20

notwithstanding [1] - 11:24

Number[1] - 9:24

number[5] - 5:3, 5:16, 17:15, 27:18

numbers [1] - 25:11

Numbers [1] - 9:18

O

object [1] - 20:10

objection [2] - 20:13, 27:5

objections [1] - 18:1

obligation [1] - 23:22

obligations [1] - 25:6

obviously [5] - 16:23, 19:24, 22:10,

22:13, 22:15

occurred [1] - 23:18

odd [1] - 21:2

OF [5] - 1:1, 1:8, 1:10, 2:12, 31:16

offenses [1] - 27:21

offer[1] - 30:23

office [2] - 20:20, 23:12

OFFICE [1] - 2:12

official [1] - 31:6

Official [2] - 2:16, 31:24

once [3] - 8:21, 29:12, 29:18

one [16] - 7:10, 7:11, 7:14, 8:22, 9:2,

9:14, 10:4, 10:7, 17:15, 20:1, 22:9, 23:7,

24:19, 28:8, 28:18, 31:4

ones [1] - 17:7

open [1] - 3:1

opportunity [7] - 9:13, 14:2, 15:4, 16:17,

20:7, 21:20, 22:5

optimism [1] - 16:25

options [2] - 11:2, 15:5

order[9] - 4:7, 14:7, 15:25, 16:19, 20:2,

24:21, 25:24, 26:3, 30:4

ordering [1] - 27:6

organization [1] - 21:24

original [2] - 16:22, 20:2

ourselves [1] - 25:10

outset [1] - 5:6

overarching [1] - 29:8

overnight [1] - 18:6

own [3] - 7:5, 17:3, 17:13

P

P.A [1] - 1:17

p.m [1] - 1:8

Package [1] - 7:12

page [1] - 14:7

pages [1] - 30:3

painting [1] - 21:25

pants [1] - 20:22

paper[1] - 30:6

paradigm [1] - 13:3

parallel [1] - 14:24

Pardon [1] - 7:12

Park Avenue [1] - 1:19

part [4] - 17:24, 18:16, 20:9, 23:12

parte [2] - 16:11, 21:9

particular[1] - 6:21

Particularity [1] - 13:13

particularly [1] - 21:3

parties [4] - 10:22, 16:11, 17:16, 21:12

partisan [1] - 21:24

party [2] - 17:3, 20:14

past [1] - 15:6

Pavlovian [1] - 6:8

paying [1] - 25:9

payment[1] - 25:1

Pennsylvania [2] - 1:15, 2:8

people [3] - 20:17, 20:19, 23:15

perfectly [1] - 28:21

perhaps [1] - 21:20

period [1] - 4:25

Anthony D. Frisolone, FAPR, RDR, CRR, CRI, CSR

Official Court Reporter

(minimum - privileged) Page 5

person [1] - 23:8

personal [2] - 12:10, 20:20

perspective [2] - 13:5, 20:10

photographs [1] - 18:15

physical [1] - 14:14

physically [2] - 18:21, 23:11

pick [2] - 9:15, 9:16

place [4] - 15:25, 26:7, 29:12, 29:19

plain [2] - 14:7, 14:8

Plaintiff [6] - 1:4, 1:13, 1:14, 1:18, 1:22,

2:3

plaintiff [8] - 3:8, 3:10, 4:22, 5:8, 6:23,

22:11, 29:21

plaintiff's [11] - 5:3, 7:4, 8:20, 8:21,

8:25, 20:10, 25:23, 27:6, 30:4, 30:19,

30:21

plan [7] - 6:18, 13:18, 13:22, 13:24,

16:5, 16:25, 18:1

plans [1] - 16:22

play [5] - 5:1, 5:11, 6:10, 8:3, 11:13

plea [1] - 20:22

pleading [1] - 14:3

pleadings [1] - 12:7

pleasure [1] - 3:12

PLLC [1] - 1:13

point [17] - 7:18, 11:2, 12:8, 12:19, 13:4,

13:17, 13:21, 15:11, 16:18, 21:15, 22:14,

26:5, 26:10, 27:14, 28:18, 28:22, 30:14

points [2] - 25:18, 29:4

political [1] - 21:24

politicized [3] - 20:17, 21:1, 21:2

posed [1] - 16:5

position [14] - 4:19, 7:7, 8:23, 11:1,

14:13, 15:2, 15:8, 19:13, 19:21, 20:11,

25:22, 26:14, 26:23, 27:12

possessive [1] - 4:22

possible [1] - 27:21

potential [1] - 20:13

potentially [5] - 10:8, 16:7, 19:5, 23:20

PRA [1] - 28:25

practical [1] - 22:15

Pratt [1] - 2:4

preconceived [1] - 26:19

preexisting [1] - 7:4

preliminary [2] - 4:9, 6:13

premature [1] - 13:5

PREMOTION [1] - 1:10

prerogative [1] - 11:21

presented [1] - 4:3

presenting [1] - 15:12

President [3] - 12:11, 28:24, 29:1

president's [1] - 26:12

President's [1] - 28:5

presidential [4] - 12:10, 26:13, 28:24,

29:3

Presidential Records Act [5] - 4:15,

12:8, 13:11, 21:5, 28:25

presumably [2] - 11:10, 24:2

prevailing [1] - 26:25

prima [6] - 11:18, 11:21, 12:18, 12:24,

13:2, 13:20

primary [1] - 24:16

privilege [5] - 4:14, 5:4, 5:14, 12:1,

30:21

privileged [2] - 10:8, 10:9

Case 9:22-cv-81294-AMC Document 147 Entered on FLSD Docket 10/13/2022 Page 36 of 38
problem [2] - 18:9, 23:3

Procedure [1] - 14:10

proceed [1] - 4:23

proceedings [1] - 31:18

Proceedings [1] - 2:19

process [7] - 6:14, 6:21, 13:6, 17:18,

18:18, 20:9, 24:23

produced [1] - 2:19

production [2] - 15:23, 16:8

progress [4] - 29:13, 29:14, 29:15,

30:12

properly [1] - 21:10

property [5] - 4:12, 4:16, 5:24, 6:3, 14:9

proposed [3] - 16:23, 18:2, 25:24

protective [1] - 28:17

provide [10] - 4:8, 8:10, 8:23, 10:6, 11:3,

25:22, 27:6, 30:6, 30:19

provided [3] - 8:20, 27:22, 30:4

providing [3] - 13:19, 19:21, 31:6

public [2] - 20:25, 31:7

pure [1] - 19:25

purport [1] - 14:15

purposefully [1] - 11:15

purposes [1] - 24:15

pursuant [1] - 30:3

pushing [1] - 23:14

put [1] - 20:18

putting [1] - 21:23

Q

questions [2] - 8:12, 22:10

quibble [1] - 18:23

quibbling [1] - 21:17

quick [2] - 28:1, 31:4

quickly [4] - 8:9, 9:5, 9:8, 9:13

quite [1] - 6:14

R

raid [1] - 28:10

raise [1] - 22:9

raised [1] - 15:1

raises [1] - 13:25

range [1] - 5:5

rather[1] - 22:1

RAYMOND [1] - 1:11

reaching [1] - 16:15

real [2] - 6:2, 8:5

realistic [3] - 15:25, 16:5, 19:1

reality [1] - 17:5

realize [2] - 3:19, 5:10

really [3] - 4:10, 18:5, 19:4

reason [3] - 9:2, 11:17, 11:19

reasons [1] - 27:17

received [2] - 7:9, 16:24

recent [3] - 20:14, 20:16, 22:19

recommendation [3] - 5:13, 5:18, 24:3

recommendations [1] - 15:9

record [6] - 3:7, 7:15, 26:13, 29:3,

29:24, 31:18

recorded [1] - 2:19

Records [1] - 12:1

records [4] - 12:11, 16:8, 28:25, 29:1

redact [1] - 31:8

regarding [1] - 4:14

reiterate [1] - 27:14

relating [2] - 15:3, 20:21

relatively [2] - 4:25, 17:4

relief [2] - 5:10, 10:17

relies [1] - 13:11

remember[2] - 18:2, 20:5

remembering [1] - 14:23

remove [1] - 8:16

Reporter[3] - 2:16, 2:16, 31:24

REPORTER [1] - 31:16

reports [1] - 15:8

representation [1] - 7:19

representative[1] - 29:25

request [1] - 9:19

requested [1] - 11:4

require [2] - 7:2, 26:11

resolution [4] - 5:13, 14:22, 17:20,

28:12

resolve [1] - 17:12

resolved [1] - 4:21

respect [11] - 5:11, 11:5, 24:20, 25:20,

26:3, 27:8, 29:2, 30:15, 30:20, 31:5, 31:7

respective [1] - 16:14

respond [2] - 22:10, 25:17

responding [1] - 17:8

response [3] - 24:20, 28:2, 28:22

responsibility [1] - 5:5

responsible [2] - 4:24, 24:22

responsibly [1] - 5:17

restrict [1] - 22:24

restricts [1] - 22:17

return [2] - 4:16, 14:8

review [5] - 9:14, 18:14, 18:19, 23:17

rigidly [1] - 6:15

rolling [3] - 9:10, 17:4, 18:19

roughly [1] - 14:24

Rule [10] - 4:16, 7:11, 12:8, 13:10,

13:25, 14:3, 14:9, 19:15, 28:16

Rules [1] - 14:9

rules [1] - 10:25

ruling [1] - 27:1

run [1] - 19:8

S

S.E [1] - 1:23

S.W [1] - 2:8

said-she [1] - 13:19

Sam's [1] - 24:13

Sandy [1] - 20:20

satisfied [1] - 23:7

scanned [1] - 25:2

scenario [3] - 17:3, 21:2, 22:20

schedule [3] - 4:4, 29:12, 29:19

scheduling [4] - 4:7, 15:25, 16:19,

25:24

scratch [1] - 7:16

search [1] - 14:25

searchable [1] - 10:2

seated [1] - 3:3

second [4] - 6:21, 7:14, 14:7, 20:1

secret [1] - 27:16

SECURITY[1] - 2:7

Anthony D. Frisolone, FAPR, RDR, CRR, CRI, CSR

Official Court Reporter

(problem - standing) Page 6

Security [1] - 28:20

see [9] - 3:12, 15:4, 23:4, 23:22, 24:1,

24:2, 27:18, 27:22, 29:6

seeing [1] - 15:15

seem [1] - 22:14

sees [1] - 22:25

seized [3] - 4:13, 4:14, 30:18

selected [2] - 9:8, 25:21

selects [1] - 8:22

sense [5] - 12:16, 13:17, 13:24, 15:6,

22:15

sensitive [4] - 11:10, 24:2, 27:20, 27:24

separate [1] - 30:19

separated [1] - 30:18

separately [2] - 10:9, 17:10

September[2] - 1:7, 17:24

seriously [1] - 24:8

served [1] - 7:20

session [1] - 16:14

set [2] - 19:6, 30:23

setting [1] - 20:25

several [1] - 30:1

share [2] - 6:13, 27:15

shirts [1] - 18:16

shopping [1] - 9:7

short [3] - 4:25, 17:7, 19:8

shortcomings [1] - 6:24

shortly [2] - 4:6, 5:21

show [1] - 25:10

shown [1] - 20:24

side [4] - 7:4, 21:22, 22:23, 24:13

sides [1] - 24:8

sifting [1] - 13:7

signing [1] - 31:8

SILVERMAN [1] - 2:2

simmer[1] - 17:12

simply [1] - 12:23

sincere [1] - 21:14

sit [1] - 6:9

sitting [2] - 6:5, 23:11

slew [1] - 15:19

slow [1] - 23:16

SLUTKIN [1] - 2:2

solicited [1] - 21:12

someone [1] - 12:11

soon [1] - 8:24

sorry [2] - 17:22, 21:15

sort [1] - 16:16

sorting [1] - 28:6

sorts [2] - 5:10, 28:17

SOUTHERN [1] - 2:12

Southern [1] - 3:16

special [5] - 11:13, 13:8, 21:3, 21:16

Special [3] - 3:5, 20:3, 21:16

SPECIAL [1] - 1:11

specific [1] - 18:22

specifics [1] - 7:12

speed [1] - 18:11

spirit [1] - 17:14

spokespeople [1] - 24:14

spokesperson [1] - 24:14

spreadsheet[2] - 30:16, 30:19

stage [1] - 19:22

stamped [1] - 25:3

standing [1] - 6:8

Case 9:22-cv-81294-AMC Document 147 Entered on FLSD Docket 10/13/2022 Page 37 of 38
starting [5] - 3:8, 7:7, 7:8, 7:16, 12:19

state [1] - 3:7

statements [1] - 19:14

status [2] - 4:13, 26:23

stay [1] - 11:1

stenography [1] - 2:19

steps [2] - 12:19, 15:11

Steve [1] - 3:17

STEVE [1] - 2:10

still [2] - 22:10, 22:15

stored [1] - 26:6

strange [2] - 21:7, 22:20

strategies [1] - 5:11

strategy [2] - 5:12, 6:22

Street [2] - 2:4, 2:14

strong [1] - 23:21

strongly [1] - 20:8

study [1] - 5:25

stuffed [1] - 20:22

submit [2] - 7:16, 21:6

submitted [2] - 6:18, 23:6

submitting [1] - 16:23

subset [1] - 4:21

substantiate [1] - 19:14

substantive [1] - 15:3

substantively [1] - 19:3

sufficient [1] - 27:18

suggest [2] - 18:4, 18:9

suggested [1] - 27:7

suggesting [1] - 15:10

Suite [4] - 1:15, 1:19, 1:23, 2:4

Sunday [1] - 19:7

supersede [1] - 12:9

support [1] - 15:13

suppose [1] - 6:15

supposed [1] - 26:5

suppress [1] - 14:25

Supreme [1] - 27:1

swear[1] - 15:20

systems [1] - 24:24

T

table [1] - 11:8

Tallahassee [1] - 1:20

tasks [1] - 4:3

team [5] - 10:8, 22:18, 27:20, 29:25,

30:17

team's [1] - 30:2

teed [1] - 14:21

telegraphed [1] - 12:7

Telephone [1] - 2:17

terms [8] - 5:2, 6:14, 13:4, 13:21, 15:24,

16:22, 18:24, 19:1

the Defendant [3] - 2:6, 2:7, 2:13

theories [1] - 13:9

thinks [2] - 16:4, 16:6

third [1] - 17:3

third-party [1] - 17:3

THOMPSON [1] - 2:2

three [2] - 4:20, 17:18

three-week [1] - 17:18

throw [1] - 9:9

thrown [1] - 25:9

Thursday [3] - 9:16, 17:7, 17:8

timeframe [1] - 11:4

timeline [1] - 25:20

timing [1] - 18:24

today [5] - 4:7, 8:22, 15:11, 19:9, 25:9

tomorrow [5] - 8:24, 9:16, 9:17, 24:25,

31:6

Tony [1] - 3:15

took [1] - 20:7

top [2] - 18:3, 27:16

totally [1] - 23:10

touch [1] - 29:18

touched [1] - 16:16

traditional [1] - 12:9

train [1] - 17:17

Transcript[1] - 2:19

transcript [1] - 31:17

TRANSCRIPT[1] - 1:10

Transcription [1] - 2:19

translate [1] - 18:13

treat [1] - 22:23

trigger[1] - 20:19

TRUMP[1] - 1:3

Trump [5] - 1:14, 1:18, 1:22, 2:3, 3:6

Trump's [1] - 28:24

Trusty [2] - 3:10, 30:24

trusty [6] - 22:24, 24:20, 25:4, 25:18,

27:16, 28:3

TRUSTY[29] - 1:16, 3:9, 6:4, 6:8, 6:12,

8:7, 9:4, 9:12, 12:2, 12:6, 13:3, 14:11,

14:21, 15:17, 16:21, 17:22, 17:24, 18:8,

19:19, 22:7, 22:9, 24:7, 24:11, 25:7,

25:15, 28:1, 28:4, 28:14, 29:21

try [4] - 3:21, 6:9, 9:8, 12:3

trying [1] - 17:16

TS [1] - 22:18

Tuesday [1] - 1:7

turn [1] - 5:21

tutorial [1] - 26:20

tweets [1] - 28:24

two [7] - 7:9, 10:6, 16:7, 17:2, 17:16,

19:4, 28:1

U

U.S [3] - 7:15, 20:18, 23:9

ultimate [1] - 12:17

ultimately [3] - 4:13, 26:24, 27:10

Uncle [1] - 24:13

under [14] - 4:15, 7:10, 12:1, 14:3, 14:9,

14:12, 15:5, 17:3, 24:21, 26:25, 27:9,

28:17, 28:25

understood [5] - 5:15, 10:10, 19:19,

24:7, 26:21

unfettered [2] - 12:12, 12:13

unintentionally [1] - 15:7

United States [10] - 1:1, 1:8, 1:5, 2:6,

2:8, 2:12, 2:13, 3:6, 12:12, 29:24

universe [1] - 12:10

unnecessarily [1] - 23:17

up [4] - 6:9, 14:21, 19:7, 30:23

urge [1] - 20:8

Anthony D. Frisolone, FAPR, RDR, CRR, CRI, CSR

Official Court Reporter

(starting - §41(g)) Page 7

V

vacuum [1] - 22:21

various [1] - 6:2

vendor[8] - 8:23, 9:7, 9:8, 9:15, 9:16,

18:18, 24:25, 25:21

vendors [9] - 8:21, 9:3, 9:11, 9:20,

18:13, 19:1, 24:21, 24:23, 25:8

verification [1] - 5:23

verify [2] - 4:11, 11:11

version [1] - 31:8

versions [1] - 17:6

versus [1] - 3:6

vested [1] - 29:1

viability [1] - 5:14

view [1] - 19:17

violation [1] - 13:12

Virginia [1] - 22:19

W

wait [1] - 21:11

wants [2] - 11:8, 27:8

warning [1] - 20:18

warrant [2] - 13:12, 14:25

Washington [2] - 1:16, 2:9

ways [2] - 6:19, 18:13

week [4] - 17:18, 17:21, 17:23, 25:22

weeks [1] - 17:22

weigh [2] - 16:17, 21:21

welcome [2] - 3:14, 3:19

WHITE [1] - 2:2

willing [1] - 23:4

witness [2] - 19:13, 20:13

witnesses [1] - 21:12

word [2] - 15:21, 29:14

workload [1] - 5:2

writing [1] - 29:7

written [1] - 17:17

Y

years [1] - 22:20

yesterday[5] - 4:4, 6:18, 6:19, 8:19,

20:8

YORK [1] - 1:1

York [2] - 1:5, 3:20

§

§41(g [4] - 14:12, 14:24, 15:9, 19:23

§41(g) [2] - 15:5, 15:13

Case 9:22-cv-81294-AMC Document 147 Entered on FLSD Docket 10/13/2022 Page 38 of 38