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Rh 425 F.3d 971, 974 (11th Cir. 2005); see also Richey v. Smith, 515 F.2d 1239, 1243–44 (5th Cir. 1975) (court must consider “whether the plaintiff has an individual interest in and need for the material whose return he seeks”); 3A Charles Alan Wright and Sarah N. Welling, Fed. Prac. & Proc. § 690, at 248 (4th ed. 2010).

Plaintiff has no property interest in any Presidential records (including classified records) seized from the Premises. The Presidential Records Act provides—under a heading entitled “Ownership of Presidential records”—that “[t]he United States shall reserve and retain complete ownership, possession, and control of Presidential records.” 44 U.S.C. § 2202; see ''Citizens for Responsibility & Ethics in Wash. v. Trump'', 924 F.3d 602, 603 (D.C. Cir. 2019) (the PRA “establishes the public ownership of records created by … presidents and their staffs in the course of discharging their official duties” (brackets and internal quotations omitted)). And Presidential Records include any “documentary materials” that were “created or received by the President, the President’s immediate staff, or a unit or individual of the Executive Office of the President whose function is to advise or assist the President” while “conducting activities which relate to or have an effect upon the carrying out of the constitutional, statutory, or other official or ceremonial duties of the President.” 44 U.S.C. § 2201(2).

Neither of Plaintiff’s filings addresses or even cites that statutory provision. Nor does Plaintiff offer any other colorable argument that he has a property interest in any Presidential records seized. Plaintiff’s Motion, in fact, asserts that “[t]he documents seized at Mar-a-Lago