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November 12, 2022

Via 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 

– Scanned Material Log and Filter A, C Documents

Dear Judge Dearie:

We submit the following letter to supplement the Defendant’s submission to you today 

and to confirm,

(1) The Scanned Materials Log submitted by the Defendant appears to accurately 

reflect Plaintiff’s position on the scanned materials, as reflected in our November 

2, 2022, log, which was circulated via email; and

(2) The additions highlighted in green in the Filter Table submitted today by the 

Defendant appear to accurately reflect Plaintiff’s position as to those materials. 

We note that, to the extent to which the Special Master does not concur with Plaintiff’s 

designations that are marked exclusively “personal,” Plaintiff reserves the right to argue 

that such documents are “personal” pursuant to Judicial Watch v. NARA – i.e., that these 

are items created or received during the Trump presidency that can be possessed postpresidency as personal.”

Further, the Defendant’s cover letter contains legal arguments. We respectfully request 

that you disregard these portions of the cover letter, as they are tantamount to an additional 

brief not contemplated by the scheduling order. The tasks before the Special Master do 

not include making findings as to hypothetical uses of seized personal documents and the 

parties were directed to make the Special Master aware of their position on “global issues” 

relating to the categorization of documents. That was done in separate filings. While the 

entirety of this litigation is within the framework of Rule 41, ECF 64 at 6, 14 (describing 

Case 9:22-cv-81294-AMC Document 178-1 Entered on FLSD Docket 11/12/2022 Page 1 of 3
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the matters relevant to the Special Master’s review as “bound up with” Rule 41), the issue 

of Government retention of documents is not yet before the Court. 

Finally, consistent with the requested briefing order of the Special Master, the Plaintiff 

does not waive his ability to raise additional categorization issues as to specific documents 

or groups of documents. While the joint log provides a description of the basis for each 

item’s categorization, we believe each party maintains the ability to discuss in more detail 

their position as to various specific items, which could be accommodated at the December 

1 status conference, or at another time convenient to the Special Master.

Sincerely,

James M. Trusty

Ifrah Law PLLC

1717 Pennsylvania Ave. NW, Suite 650

Washington, D.C. 20006

Telephone: (202) 524-4176

Email: jtrusty@ifrahlaw.com

Christopher M. Kise

Chris Kise & Associates, P.A.

201 East Park Avenue, 5th Floor

Tallahassee, FL 32301

Telephone: (850) 270-0566

Email: chris@ckise.net

Lindsey Halligan

Florida Bar No. 109481 

511 SE 5th Avenue

Fort Lauderdale, FL 33301

Email: lindseyhalligan@outlook.com

Case 9:22-cv-81294-AMC Document 178-1 Entered on FLSD Docket 11/12/2022 Page 2 of 3
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M. Evan Corcoran 

Silverman Thompson Slutkin White, LLC

400 East Pratt Street – Suite 900 

Baltimore, MD 21202 

Telephone: (410) 385-2225 

Email: ecorcoran@silvermanthompson.com 

Counsel for Plaintiff President Donald J. 

Trump

CC: Jay I. Bratt, jay.bratt2@usdoj.gov

Julie A. Edelstein, julie.edelstein@usdoj.gov

Stephen Marzen, Stephen.Marzen@usdoj.gov>

Juan Antonio Gonzalez, Jr., juan.antonio.gonzalez@usdoj.gov

Case 9:22-cv-81294-AMC Document 178-1 Entered on FLSD Docket 11/12/2022 Page 3 of 3