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Rh The Privilege Review Team Has Completed Its Work

The privilege review team has completed its review of the materials in its custody and control that were identified as potentially privileged. The privilege review team identified only a limited subset of potentially attorney-client privileged documents. Pursuant to the court-approved filter protocols, the privilege review team was permitted to

"(a) apply ex parte to the court for a determination whether or not the documents contain attorney-client privileged material; (b) defer seeking court intervention and continue to keep the documents inaccessible to law-enforcement personnel assigned to the investigation; or (c) disclose the documents to the potential privilege holder, request the privilege holder to state whether the potential privilege holder asserts attorney-client privilege as to any documents, including requesting a particularized privilege log, and seek a ruling from the court regarding any attorney-client privilege claims as to which the Privilege Review Team and the privilege-holder cannot reach agreement."

MJ Docket D.E. 102-1 at ¶ 84.

Having completed its review of materials identified as potentially privileged, the privilege review team is prepared, pending direction from the Court, to proceed in accordance with the above procedures.

Plaintiff Lacks Standing to Seek Judicial Oversight and Related Relief in Relation to Any Presidential Records Seized from the Premises

Plaintiff asks for a special master and related relief in anticipation of moving for the return of property under Criminal Rule 41(g). As he asserted: “[T]he requested relief is necessary to ensure that Movant can properly evaluate and avail himself of the important protections of Rule 41 of the Federal Rules of Criminal Procedure, particularly the ability to move for the return of seized property under Rule 41(g).” D.E. 28 at 4.

But, “[i]n order for an owner of property to invoke Rule 41(g), he must show that he had a possessory interest in the property seized by the government.” United States v. Howell,