UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

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DONALD J. TRUMP,

Plaintiff,

STAFFING, COMPENSATION,

- against - AND EXPENSE PROPOSAL 

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 No. 104, the undersigned submits this 

staffing, compensation, and expense proposal. 

In both the Case Management Plan filed on September 22, 2022, ECF 106 (“Plan”), and 

the Amended Case Management Plan filed on September 23, 2022 (“Amended Plan”), the 

undersigned notified the parties as follows:

The undersigned has determined that the efficient administration of the Special 

Master’s duties requires the assistance of the Honorable James Orenstein (Ret.), a 

former United States Magistrate Judge for the Eastern District of New York, who 

has experience with complex case management, privilege review, warrant 

procedures, and other matters that may arise in the course of the Special Master’s 

duties. Judge Orenstein has served as an appointed amicus curiae in the Foreign 

Intelligence Surveillance Court pursuant to 50 U.S.C. § 1803(i)(2) and currently 

holds Top Secret clearance.

The undersigned will also utilize Eastern District of New York court staff in 

carrying out his duties as Special Master. The undersigned will promptly notify 

the parties of any need for additional professionals, support staff, or expert 

consultants.

As a United States District Judge in active service, the undersigned will seek no 

additional compensation for performing the duties of Special Master in this 

action. The undersigned proposes that Judge Orenstein be compensated at the 

hourly rate of $500. The undersigned further proposes that the Special Master will 

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provide the parties with monthly invoices, starting on October 1, 2022, setting 

forth the hours worked and expenses to be reimbursed. No later than seven 

calendar days after receiving each such invoice, Plaintiff shall notify the 

undersigned of any objections to the invoice, which will be promptly reviewed 

and resolved. No later than seven calendar days after the undersigned has resolved 

any such disputes (or seven calendar days after receiving an invoice as to which 

Plaintiff raises no objections), Plaintiff will submit payment in full as directed on

the invoice. Failure to make timely payment will be deemed a violation of the 

Special Master’s order subject to sanction pursuant to Federal Rule of Civil 

Procedure 53(c)(2).

The parties may submit comments on the foregoing staffing, compensation, and 

expense proposal no later than September 24, 2022, after which time the 

undersigned shall submit the proposal to the Court for consideration and approval. 

See Appointing Order, ¶¶ 14-15. 

Plan at 5-6; Amended Plan at 5-6. 

No party has submitted any comment to the foregoing proposal, and the time for such 

comment has lapsed. Accordingly, the undersigned respectfully submits the foregoing proposal 

to the Court for approval. 

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

September 27, 2022 RAYMOND J. DEARIE

 United States District Judge

Case 9:22-cv-81294-AMC Document 117 Entered on FLSD Docket 09/27/2022 Page 2 of 2