1 

U.S. Department of Justice 

National Security Division

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

 November 16, 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 – 

Corrected Logs of Disputed Documents for Report and Recommendation 

 

Dear Judge Dearie:

The discrepancies in the Scanned Materials Log identified in ECF 185 are corrected in a revised 

log as follows: 

• The revised log adds the missing row for SM_MAL-00000011 to SM_MAL-00000012 – 

there is no dispute for the Special Master to resolve; 

• The revised log corrects the government’s designation of three documents to Presidential 

records from personal records (SM_MAL-00018439 to SM_MAL-00018444, SM_MAL00020243, and SM_MAL-00021523 to SM_MAL-00021528) – there is no dispute for the 

Special Master to resolve; and 

• The revised log removes the government’s dual designations of four documents, which 

was in error (SM_MAL-00001541, SM_MAL-00004502 to SM_MAL-00004503, 

SM_MAL-00004789 to SM_MAL-00004790, and SM_MAL-00018583 to SM_MAL00018603) – three of the documents are designated by the government as Presidential 

records and remain in dispute; one record is designated by the government as a personal 

record and is no longer in dispute. 

In reviewing the Scanned Materials Log, the government also identified additional errors. The 

revised Scanned Materials Log is submitted to the Special Master with the courtesy copy of this 

letter. 

The discrepancy in the Filter Materials Log with respect to Filter Document 22, C-001, is 

corrected in the table that begins on the next page. The parties have no dispute as to the 

categorization of Filter Log Document 22 as personal and unprivileged. 

Case 9:22-cv-81294-AMC Document 187-1 Entered on FLSD Docket 11/16/2022 Page 1 of 5
2 

Filter Document Log Reference 

Number

Filter Bates 

Number(s)

Document 

Categorization

Privilege Status 

(Executive Privilege Only)

1 A-001 Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Dispute 

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

2 A-002 to A003Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

3 A-004 Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

4 A-005 Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

5 A-006 to A016Agreed

Plaintiff: personal 

records

Government: 

personal records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

6 A-017 to A018Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Dispute 

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

7 A-019 to A020Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

8 (portion) A-021 to A022 and A025 to A-026Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

[UPDATED] Dispute 

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

8 (portion) A-023 to A024Dispute

Plaintiff: personal 

records (Judicial 

Watch) 

Government: 

Presidential 

records

Dispute

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

Case 9:22-cv-81294-AMC Document 187-1 Entered on FLSD Docket 11/16/2022 Page 2 of 5
3 

Filter Document Log Reference 

Number

Filter Bates 

Number(s)

Document 

Categorization

Privilege Status 

(Executive Privilege Only)

9 A-029-A-030 [UPDATED] 

Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

10 A-031 to A032Dispute

Plaintiff: personal 

records (Judicial 

Watch) 

Government: 

Presidential 

records

Dispute

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

11 A-033 [UPDATED] 

Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

12 (portion) A-034 to A035Dispute

Plaintiff: personal 

records (Judicial 

Watch) 

Government: 

Presidential 

records

Dispute

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

12 A-036 to

A040

Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

[UPDATED] Dispute 

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch 

(N.B. Part of document 12 

was withheld from the 

government Case Team 

because Plaintiff claims 

attorney-client privilege and 

work product immunity)

13 (portion) A-041 to A042Dispute

Plaintiff: personal 

records (Judicial 

Watch) 

Government: 

Presidential 

records

Dispute

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

13 A-043 to

A052

Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

[UPDATED] Dispute 

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch 

(N.B. Part of document 13 

was withheld from the 

government Case Team 

Case 9:22-cv-81294-AMC Document 187-1 Entered on FLSD Docket 11/16/2022 Page 3 of 5
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Filter Document Log Reference 

Number

Filter Bates 

Number(s)

Document 

Categorization

Privilege Status 

(Executive Privilege Only)

because Plaintiff claims 

attorney-client privilege and 

work product immunity)

14 A-053 Agreed: personal 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

15 A-054 Agreed: personal 

records

Dispute 

Plaintiff: Executive privilege

Government: no Executive 

privilege 

16 A-055 Agreed: personal 

records

Dispute 

Plaintiff: Executive privilege

Government: no Executive 

privilege 

17 A-056 to A058Agreed: personal 

records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

19 A-065 to A091Agreed

Plaintiff: personal 

records

Government: 

personal records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

20 A-092 to A098Agreed

Plaintiff: personal 

records

Government: 

personal records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

21 A-099 to A137Agreed

Plaintiff: personal 

records

Government: 

personal records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

22 C-001 Agreed

Plaintiff: personal 

records

Government: 

personal records

Agreed: no claim of 

Executive Privilege by 

Plaintiff

SM_MAL_00001185 to 

SM_MAL_00001195 excluding 

SM_MAL_00001190, which is the 

subject of a separate letter from 

the Filter Team

Dispute

Plaintiff: personal 

records

Government: 

Presidential 

records

Dispute

Plaintiff: Executive privilege

Government: no privilege 

against Executive Branch

Case 9:22-cv-81294-AMC Document 187-1 Entered on FLSD Docket 11/16/2022 Page 4 of 5
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The parties regret the discrepancies. Should any further discrepancies be identified, the parties 

will address them promptly. 

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 187-1 Entered on FLSD Docket 11/16/2022 Page 5 of 5