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Read Trump Lawyers’ Filing on Mar-a-Lago Raid and Attorney-Client Privilege in Documents Case

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Read Trump Lawyers’ Filing on Mar-a-Lago Raid and Attorney-Client Privilege in Documents Case

Case 9:23-cr-80101-AMC Document 566 Entered on FLSD Docket 05/21/2024 Page 19 of 28
aggressive position in the opening submission, they agreed to “seek[] only Per. 18’s fact work
product.” Id.
Following a March 9, 2023, hearing attended by the Special Counsel’s Office and counsel
for President Trump and Per. 18, Judge Howell granted, in part, and denied, in part, the motion.
Ex. 17. The court ordered Per. 18 to produce documents “reflecting his efforts to comply” with
the Trump Office Subpoena, and that “may have informed his knowledge” of the Trump
Organization Subpoena. Judge Howell also required Per. 18 to produce the May 2022
Recording and the June 2022 Recording, based on reasoning set forth in separate orders. Exs. 18,
19. On March 22, 2023, the D.C. Circuit denied motions by President Trump and Per. 18 to stay
Judge Howell’s rulings. See Order, In re Sealed Case, Nos. 23-3035, 23-3036 (D.C. Cir. Mar. 22,
2023).
7. The Compelled Testimony
On March 24, 2023, the Special Counsel’s Office required Per. 18 and to testify
before a grand jury in the District of Columbia—despite the lack of venue for any of the offenses
under consideration. The prosecutors questioned Per. 18 extensively regarding, inter alia, the
otherwise-privileged communications with President Trump, the May 2022 Recording, and the
June 2022 Recording.
B. Applicable Law
1. Attorney-Client Privilege And Work Product
“Traditionally, the attorney-client privilege, like the privilege extending to attorney work
product, is sacrosanct.” United States v. Stein, 2023 WL 2585033, at *2 (S.D. Fla. 2023) (cleaned
up). “The attorney-client privilege attaches, of course, to confidential communications between
an attorney and client for the purposes of securing legal advice or assistance.” Drummond Co.,
17

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Fetterman unleashes on ‘dirtbag’ wing of Dems after far-left victories: ‘Orgy of socialism’

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Fetterman unleashes on ‘dirtbag’ wing of Dems after far-left victories: ‘Orgy of socialism’

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Sen. John Fetterman, D-Pa., unloaded on his own party on Sunday evening, blasting a series of victories for progressives he called “anti-America.”

“Big night for the dirtbag left,” Fetterman said, referring to New York’s recent primaries, where two members of the Democratic Socialists of America (DSA) won primaries.

“I’ve said the party is becoming an orgy of socialism. Clearly anti-America, anti-Western Civilization,” Fetterman said.

Fetterman’s striking calls give a rare look at how some moderates may view the developments on their far-left flank that have dominated the party’s momentum in recent months, sparking concern that their high visibility is dragging the party further and further left.

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FETTERMAN WARNS DEMOCRATS ‘DRIFTING FIRMLY INTO COMMUNISM’ AFTER SOCIALIST PRIMARY WINS

Sen. John Fetterman, D-Pa., speaks to reporters outside the Senate Chamber during votes on Nov. 10, 2025, on Capitol Hill in Washington, D.C. (Andrew Harnik/Getty Images)

His comments come on the heels of a handful of key progressive victories.

In Maine, Graham Platner, a controversial Democratic candidate for U.S. Senate, has attracted controversy for denying knowledge of the meaning behind a Nazi-linked tattoo, for off-color comments about race and calling himself a “communist” in a deleted Reddit post.

In New York, one DSA member, Claire Valdez, won a primary on a platform of abolishing ICE and a Green New Deal-style approach to climate change. Similarly, Darializa Avila-Chevalier, another DSA candidate, beat out incumbent Rep. Adriano Espillat, D-N.Y., a high-ranking Democrat and the chair of the Congressional Hispanic Caucus.

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WINNERS AND LOSERS EMERGE AFTER SOCIALIST EARTHQUAKE ROCKS NYC PRIMARIES

Graham Platner, Democratic Senate candidate for Maine, speaks at a primary election night event at the Blue Hill YMCA in Blue Hill, Maine, on June 9, 2026. Platner won the party’s Senate primary after a campaign marked by accusations of past misbehavior and voter concerns. (Graeme Sloan/Bloomberg via Getty Images)

Both Chevalier and Valdez had the backing of New York Mayor Zohran Mamdani, himself a socialist.

The wins have captured national attention and drawn criticisms from Republicans who have pointed to their success as emblematic of the direction of the Democratic Party.

Fetterman, who has not shied away from confrontations, has been one of the few Democrats to express alarm about the kind of candidates carrying the party’s banner.

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“I mean, you look at some of the things that people have said. Abolish prison, abolish the border, abolish ICE, I mean these crazy people — I have colleagues in my caucus that refuse to even call this out,” Fetterman said.

FETTERMAN REACTS TO MAMDANI’S REFUSAL TO ACCEPT SUPREME COURT’S IMMIGRATION RULING

U.S. Sen. John Fetterman, D-Pa., walks through the Senate Subway during the Senate War Powers vote on April 22, 2026, in Washington, D.C. (Heather Diehl/Getty Images)

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“Between P-hustle in Maine and some of the other winners in New York, they should form their own party and run on all the things that they’ve had to delete on social media,” Fetterman said, referring to Platner.

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“That’s where our party has moved,” he added.

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Supreme Court limits police use of cellphone data to find crime suspects

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Supreme Court limits police use of cellphone data to find crime suspects

The Supreme Court cast doubt Monday on whether police may obtain cellphone data to find crime suspects.

In a 6-3 decision, the justices said this location information showing where a cellphone user has traveled is personal and private and subject to the protection of the 4th Amendment’s ban on unreasonable searches.

Justice Elena Kagan said these “records serve as a personal journal of a user’s movements.”

She said the information “resembles other private materials — think of emails, documents, photographs, or calendars—that even if stored on Google’s servers, a user reasonably views as his own…and reasonably expects to be shielded from the inquisitive eyes of the government.”

Because an “individual has a legitimate expectation of privacy in his cellphone location data,” she said police investigators need a valid search warrant from a magistrate.

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The court stopped short of deciding the proper basis for a search warrant in such cases. Instead, the justices sent the case back to judges in Virginia.

But the outcome casts doubt on “geofence warrants.”

In recent years, police have gone to Google and cellphone companies seeking tracking data on cellphones that were at a crime scene. Sometimes, they have had a warrant from a magistrate.

Civil libertarians say the use of this tracking data raises the specter of mass surveillance on innocent people.

Police and government lawyers say no one has a reasonable right to privacy when they are walking on a sidewalk or driving down the street.

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The case before the court arose from the armed robbery conviction of a Virginia man who stole $195,000 from a credit union in a small town near Richmond.

By the time police arrived, the robber had fled. But surveillance cameras showed he was carrying a gun and a cellphone.

Lacking other leads, detective Joshua Hilton asked a judge to issue a special type of warrant seeking information from Google.
Referred to as a “geofence warrant,” it seeks data from phones in a particular area at a particular time.

The detective sought data on phones that were within 150 yards of the credit union within one hour of the late afternoon robbery.

After examining and paring down the data, the detective asked for the phone records of Okello Chatrie. Then, with a search warrant of his home, investigators found two robbery-style demand notes, a semi-automatic pistol and about $100,000 in cash.

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A judge refused to suppress the evidence from an allegedly unconstitutional search, and Chatrie entered a conditional guilty plea.
The full 4th Circuit Court of Appeals split evenly on the legality of the geofence warrant, and the Supreme Court agreed to decide the issue in Chatrie vs. U.S.

Usually investigators obtain warrants to search the home or vehicle of a known crime suspect.

The new and disputed geofence warrants seek to find a suspect by examining data on the cellphones that were at the scene of a crime.

The FBI used this cellphone data in 2021 to identify suspects who broke through police barricades on Jan. 6, 2021, and pushed their way into the Capitol to disrupt the official counting of electoral votes.

Chief Justice John G. Roberts Jr. and Justices Sonia Sotomayor, Neil M. Gorsuch, Brett M. Kavanaugh and Ketanji Brown Jackson agreed on the outcome in Chatrie vs. U.S.

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In a 21-page dissent, Justice Samuel A. Alito Jr. said the court had “carefully set the stage for its planned performance: striking a pose as a great champion of privacy in the digital age. I cannot support this irresponsible escapade.”

Justice Clarence Thomas agreed.

Justice Amy Coney Barrett agreed in a one-paragraph dissent. “Chatrie had no reasonable expectation of privacy in data about his public movements that he voluntarily disclosed to Google,” she said.

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Supreme Court Expands Presidential Powers to Fire Independent Regulators

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The Supreme Court ruled 6-3 that President Trump could fire independent regulators for any reason. But the justices carved out an exception for the Federal Reserve, preventing the immediate removal of Lisa D. Cook, a Federal Reserve governor.

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