UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

CASE NO. 22-CV-81294-CANNON

DONALD J. TRUMP,

Plaintiff,

v. 

UNITED STATES OF AMERICA, 

Defendant. 

________________________________/ 

JOINT MOTION TO FILE 

REDACTED AND UNREDACTED GLOBAL ISSUES BRIEFS UNDER SEAL

The United States of America and Plaintiff Donald J. Trump jointly move this Court 

to file under seal their briefs to the Special Master concerning certain “global issues” identified 

in the course of the Special Master’s review process. See Docket Entry (“D.E.”) 161-1, 162. 

Each party will file two versions of its respective memoranda under seal (for a total of 

four documents). The first version will consist of the party’s full, unredacted response to the 

five issues identified in D.E. 161-1. The second version will be the same document but with

the party’s proposed redactions of selected paragraphs.

The reason for those redactions is that each party’s pleadings will discuss certain 

Seized Materials or certain categories of Seized Materials. Under the Protective Order issued 

by the Special Master, the parties understand that those parts of their pleadings should not be 

disclosed publicly. See D.E. 113 ¶ 3 (“Nothing herein shall prevent a party from using Seized 

Materials as exhibits to pleadings or otherwise, or from referring to, quoting, or reciting from 

Case 9:22-cv-81294-AMC Document 168 Entered on FLSD Docket 11/08/2022 Page 1 of 3
Seized Materials in connection with pleadings or motions filed in the above-captioned case; 

provided, however, that any such Seized Materials be filed under seal or submitted to the Special 

Master or Court for in camera inspection.”).

After the parties have exchanged their respective proposed redacted filings, the parties 

will move the Court separately to unseal the redacted versions of their memoranda. If and 

when the Court grants those forthcoming motions to unseal, the redacted versions of the 

memoranda can be filed publicly on the docket. Until that motions practice is complete, 

neither party will file its “global issues” briefs on the public docket in any form.

Counsel for Plaintiff Donald J. Trump and counsel for the United States have 

conferred and have agreed on this procedure, which safeguards the interests in keeping the 

contents of the Seized Materials confidential at this time and satisfies the dictates of the 

Special Master’s Protective Order, D.E. 113. Both parties, once they have had an opportunity 

to review each other’s filings and proposed redactions, will promptly move to unseal a 

redacted version of their pleadings.

WHEREFORE, the United States and Plaintiff Donald J. Trump respectfully request 

permission to file later today their “global issues” briefs to the Special Master under seal, 

along with duplicate versions of those briefs that contain the parties’ proposed redactions (and 

which the parties intend to move to unseal at the appropriate time).

Case 9:22-cv-81294-AMC Document 168 Entered on FLSD Docket 11/08/2022 Page 2 of 3
Respectfully submitted,

 On behalf of the United States

 /s Juan Antonio Gonzalez

JUAN ANTONIO GONZALEZ 

UNITED STATES ATTORNEY

Florida Bar No. 897388

99 NE 4th Street, 8th Floor

Miami, FL 33132

Tel: 305-961-9001 

Email: juan.antonio.gonzalez@usdoj.gov

 On behalf of the Plaintiff, Donald J. Trump: 

 

/s James M. Trusty 

JAMES M. TRUSTY

Ifrah Law PLLC

CHRISTOPHER M. KISE

 Chris Kise & Associates, P.A.

LINDSEY HALLIGAN

M. EVAN CORCORAN 

Silverman, Thompson, Slutkin, White, LLC 

 

CERTIFICATE OF SERVICE

 

I HEREBY CERTIFY that on November 8, 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/ Juan Antonio Gonzalez

Juan Antonio Gonzalez

United States Attorney

Case 9:22-cv-81294-AMC Document 168 Entered on FLSD Docket 11/08/2022 Page 3 of 3