UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

WEST PALM BEACH DIVISION

DONALD J. TRUMP, 

Plaintiff, 

v. 

UNITED STATES OF AMERICA, 

Defendant. 

/ 

Case No.: 22-CV-81294-AMC 

THE NEWS MEDIA’S JOINT MOTION FOR ACCESS 

TO UNREDACTED SEARCH WARRANT AFFIDAVIT 

Intervenors American Broadcasting Companies, Inc.; the Associated Press; Bloomberg 

LP; Cable News Network, Inc.; CBS Broadcasting Inc.; Dow Jones & Company, Inc., publisher 

of The Wall Street Journal; the E.W. Scripps Company; The Palm Beach Post, a newspaper 

owned and operated by Gannett Co., Inc.; Gray Media Group, Inc. d/b/a WCJB-TV, WJHG-TV, 

and WWSB-TV; NBCUniversal Media, LLC d/b/a NBC News; The New York Times Company; 

Times Publishing Company, publisher of the Tampa Bay Times; and WP Company LLC d/b/a 

The Washington Post (the “News Media”)1 hereby move for an order further unsealing the 

affidavit of probable cause submitted in connection with the search warrant executed on August 

8, 2022 at Plaintiff Donald J. Trump’s residence at the Mar-a-Lago Club (the “Affidavit”). 

The News Media file this motion in response to Trump’s November 22, 2022 motion 

requesting that the Court order the Government to provide him with an unredacted version of the 

 

1

 The News Media were previously granted leave to intervene in this proceeding for the limited 

purpose of seeking public access to documents filed under seal. ECF No. 132. 

Case 9:22-cv-81294-AMC Document 192 Entered on FLSD Docket 11/30/2022 Page 1 of 3
2 

Affidavit. ECF No. 189.2 Trump’s motion relies in large part on the First Amendment and 

common law rights of access to judicial records. Id. at 5 & n.6. Of course, those rights belong to 

the general public, not to any individual. See Chi. Tribune Co. v. Bridgestone/Firestone, Inc., 

263 F.3d 1304, 1311 (11th Cir. 2001) (presumption of access applies to “the media and public”); 

Bright v. Mental Health Res. Ctr., Inc., 2012 U.S. Dist. LEXIS 33929, at *8 (M.D. Fla. Mar. 14, 

2012) (recognizing that “the media often acts as an advocate for the public” in seeking access to 

judicial proceedings). Therefore, if this Court unseals any additional portions of the Affidavit, 

the News Media seek access to those portions of the Affidavit as well.3 

The Government has already recognized the “public’s clear and powerful interest in 

understanding what occurred” in the search at Mar-a-Lago, which “weighs heavily in favor of 

unsealing” as much as possible. USA v. Sealed Search Warrant, No. 22-mj-8332, ECF No. 18 at 

4. Trump’s pending motion confirms that he does not assert a privacy or reputational interest in 

keeping the Affidavit under seal. See ECF No. 189 at 7-9. For these reasons, and those stated in 

their prior motions to unseal the Affidavit, see USA v. Sealed Search Warrant, No. 22-mj-8332, 

ECF Nos. 8, 22, 32, 67, 126, the News Media respectfully request that the Court grant public 

access to the Affidavit to the same extent as it grants access to Trump. 

 

2

 Magistrate Judge Bruce E. Reinhart, who signed the search warrant on August 5, 2022, has thus 

far determined which portions of the Affidavit should be unsealed under a separate docket. See 

USA v. Sealed Search Warrant, No. 22-mj-8332, ECF Nos. 80, 94, 130. Because Trump filed 

his motion to unseal in the special master proceeding, the News Media have likewise filed their 

motion under this docket. The News Media take no position on whether these motions should be 

adjudicated in this Court or under the original search warrant docket. 

3

 Trump argues that the “protective order in effect in this matter would greatly restrict access” to 

the Affidavit. ECF No. 189 at 10. But the protective order, by its terms, protects only materials 

seized during the execution of the search warrant. See ECF No. 113 at 1. It would not cover the 

Affidavit, which predates the seizure of any materials from Trump’s residence. 

Case 9:22-cv-81294-AMC Document 192 Entered on FLSD Docket 11/30/2022 Page 2 of 3
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Dated: November 30, 2022 Respectfully submitted, 

THOMAS AND LOCICERO PL BALLARD SPAHR LLP 

By: /s/ Carol Jean LoCicero By: /s/ Charles D. Tobin 

Carol Jean LoCicero (FBN 603030) 

Mark R. Caramanica (FBN 110581) 

601 South Boulevard 

Tampa, FL 33606 

Telephone: 813.984.3060 

clocicero@tlolawfirm.com 

mcaramanica@tlolawfirm.com 

Dana J. McElroy (FBN 845906) 

915 Middle River Drive, Suite 309 

Fort Lauderdale, FL 33304 

Telephone: 954.703.3418 

dmcelroy@tlolawfirm.com 

Attorneys for Intervenors The New York 

Times Company, CBS Broadcasting Inc., and 

Times Publishing Company 

Charles D. Tobin (FBN 816345) 

1909 K Street NW, 12th Floor 

Washington, DC 20006 

Telephone: 202.661.2218 

tobinc@ballardspahr.com 

Elizabeth Seidlin-Bernstein (pro hac vice) 

1735 Market Street, 51st Floor 

Philadelphia, PA 19103-7599 

Telephone: 215.665.8500 

seidline@ballardspahr.com 

Attorneys for Intervenors the Associated Press, 

Bloomberg LP, Cable News Network, Inc., Gray 

Media Group, Inc., NBCUniversal Media, LLC, 

the E.W. Scripps Company, and WP Company 

LLC 

SHULLMAN FUGATE PLLC ATHERTON GALARDI MULLEN & 

REEDER PLLC 

By: /s/ Rachel E. Fugate By: /s/ L. Martin Reeder, Jr. 

Rachel E. Fugate (FBN 144029) 

Deanna K. Shullman (FBN 514462) 

Minch Minchin (FBN 1015950) 

2101 Vista Parkway, Suite 4006 

West Palm Beach, FL 33411 

Telephone: 813.935.5098 

rfugate@shullmanfugate.com 

dshullman@shullmanfugate.com 

mminchin@shulmanfugate.com 

Attorneys for Intervenors Dow Jones & 

Company, Inc. and American Broadcasting 

Companies, Inc. 

L. Martin Reeder, Jr. (FBN 308684) 

1641 Worthington Road, Suite 11 

West Palm Beach, FL 33409 

Telephone: 561.293.2530 

martin@athertonlg.com 

Attorneys for Intervenor The Palm Beach Post 

Case 9:22-cv-81294-AMC Document 192 Entered on FLSD Docket 11/30/2022 Page 3 of 3