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’ NOTICE RESPECTING THE COURT’S APPOINTMENT OF A 

SPECIAL MASTER

On September 9, 2022, the parties submitted to this Court a joint filing, which, inter 

alia, listed each party’s proposed special master candidates. D.E. 83. In that filing, the 

government noted that it received the Plaintiff’s proposed candidates shortly after 6:00 p.m. 

on September 9, and the parties indicated that they would advise the Court about their 

respective positions on the proposed candidates on Monday, September 12, 2022. Id.

In accordance with that representation, the government hereby advises the Court that, 

because previous federal judicial experience and engagement in relevant areas of law are 

important qualifications for this position, the government submits that the Court should select 

one of the following three proposed candidates as special master: The Honorable Barbara S. 

Jones (ret.), The Honorable Thomas B. Griffith (ret.), or The Honorable Raymond J. Dearie. 1

 

1 Although Plaintiff characterized Judge Dearie as retired in the joint filing, D.E. 83, the

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Judges Jones, Griffith, and Dearie each have substantial judicial experience, during which 

they have presided over federal criminal and civil cases, including federal cases involving 

national security and privilege concerns. The government respectfully opposes the 

appointment of Paul Huck, Jr., who does not appear to have similar experience.

The government understands that each of the three candidates with prior judicial 

experience also currently employs staff who could assist in timely performing the duties 

assigned to the special master. In selecting among the three candidates, the government 

respectfully requests that the Court consider and select the candidate best positioned to timely 

perform the special master’s assigned responsibilities.2 

Respectfully submitted,

 /s Juan Antonio Gonzalez

JUAN ANTONIO GONZALEZ 

UNITED STATES ATTORNEY

 Florida Bar No. 897388

99 NE 4th Street, 8th Floor

Miami, FL 33132

Tel: 305-961-9001 

Email: juan.antonio.gonzalez@usdoj.gov

 

government’s understanding is that Judge Dearie currently remains on “senior active” 

status. If this Court were to select Judge Dearie as the special master, the government 

would defer to the Court and Judge Dearie to determine whether the special master role 

would constitute outside employment and what rules and/or restrictions, if any, would 

apply to his serving in this capacity. 

2 Prior to proposing retired Judge Jones and Judge Griffith as special master candidates, the 

government inquired as to their availability, and they both informed the government that 

they were both available immediately and have access to necessary staff to perform the work 

consistent with the schedule that the government proposes. On September 12, 2022, the 

government made the same inquiry of Judge Dearie. Judge Dearie indicated that he also 

was available and could perform the work expeditiously.

Case 9:22-cv-81294-AMC Document 86 Entered on FLSD Docket 09/12/2022 Page 2 of 4
/s Jay I. Bratt 

 JAY I. BRATT

CHIEF

Counterintelligence and Export Control

Section

National Security Division

950 Pennsylvania Avenue, NW

 Washington, D.C. 20530

Illinois Bar No. 6187361

Tel: 202-233-0986 

 Email: jay.bratt2@usdoj.gov

Case 9:22-cv-81294-AMC Document 86 Entered on FLSD Docket 09/12/2022 Page 3 of 4
CERTIFICATE OF SERVICE

 

I HEREBY CERTIFY that on September 12, 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 Juan Antonio Gonzalez

JUAN ANTONIO GONZALEZ 

UNITED STATES ATTORNEY

 Florida Bar No. 897388

99 NE 4th Street, 8th Floor

Miami, FL 33132

Tel: 305-961-9001 

Email: juan.antonio.gonzalez@usdoj.gov

Case 9:22-cv-81294-AMC Document 86 Entered on FLSD Docket 09/12/2022 Page 4 of 4