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U.S. Department of Justice 

National Security Division 

Counterintelligence and Export Control Section Washington, D.C. 20530

 October 11, 2022 

By ECF and Courtesy Copy 

Judge Raymond J. Dearie 

United States District Court 

 Eastern District of New York 

225 Cadman Plaza East 

Brooklyn, NY 11202 

Re: Donald J. Trump v. United States of America, Case No. 22-81294-CIV-CANNON – 

Government Update on Availability of Electronic Copies of Seized Materials 

 

Dear Judge Dearie: 

Consistent with Judge Cannon’s order (ECF 125, at 3), the government expects to provide 

Plaintiff and the Special Master access to electronic copies of the Seized Materials (excluding 

filter materials and documents with classification markings) tomorrow, Wednesday, October 12, 

2022. Scanning of those Seized Materials was completed this past Saturday, October 8, 2022. 

Processing of the scanned documents took place over the holiday weekend and Bates numbers 

were applied today. Tomorrow, the government expects to “make available to Plaintiff and the 

Special Master [the Seized Materials as described above] . . . in electronic format with each page 

bearing a unique Bates number.” ECF 125, at 3. We understand that the Bates range is 

SM_MAL_00000000 to SM_MAL_00021792 (Seized Materials_Mar-a-Lago), for a total 

production of 21,792 pages. 

To access electronic copies of the Seized Materials, Plaintiff’s counsel and the Special Master 

and his assistants – anyone who may access the Seized Materials under the Judicial Protective 

Order (ECF 113) – will need to provide the hosting vendor with their usernames and e-mail 

addresses. The government provided the hosting vendor’s point of contact to Plaintiff’s counsel 

on Wednesday, October 5, 2022, the same day that the government engaged the hosting vendor. 

The government is providing the hosting vendor’s point of contact to the Special Master’s 

courtroom deputy contemporaneously with this filing. 

As soon as the government provides the spreadsheet and makes available the electronic copies of 

the Seized Materials, it will file the Notice of Completion. See ECF 125, at 3-4. 

Case 9:22-cv-81294-AMC Document 140 Entered on FLSD Docket 10/11/2022 Page 1 of 3
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Thank you for your consideration. 

Respectfully submitted, 

 

 

 JUAN ANTONIO GONZALEZ 

 UNITED STATES ATTORNEY 

 MATTHEW G. OLSEN 

 Assistant Attorney General 

 By: /s/ 

 JAY I. BRATT 

 Chief 

 JULIE EDELSTEIN 

 Deputy Chief 

 STEPHEN MARZEN 

 Trial Attorney 

 Counterintelligence and Export Control Section 

 National Security Division 

 Department of Justice 

Case 9:22-cv-81294-AMC Document 140 Entered on FLSD Docket 10/11/2022 Page 2 of 3
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CERTIFICATE OF SERVICE 

 

I HEREBY CERTIFY that on October 11, 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.: +1.202.233.0986 

Email: julie.a.edelstein@usdoj.gov 

Case 9:22-cv-81294-AMC Document 140 Entered on FLSD Docket 10/11/2022 Page 3 of 3