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Rh Fourth, and independent of the three foregoing reasons, the former President could obtain the return of his personal effects under Criminal Rule 41(g) only if he satisfies the four-part Richey test. That decision established four factors that inform whether courts should entertain a Criminal Rule 41 motion for return of property before the initiation of criminal proceedings: (1) whether the movant shows that government agents “displayed a callous disregard for … constitutional rights”; (2) whether the movant has an interest in and need for the material that he seeks; (3) whether he would be irreparably injured by denial of the property; and (4) whether he has an adequate remedy at law for his grievance. Richey, 515 F.2d at 1243–44 (cleaned up). Although the former President may have a property interest in his personal effects, he cannot demonstrate callous disregard of the Fourth Amendment considering the patient exhaustion of less-intrusive methods to obtain return of documents with classification markings from the Premises and FBI Special Agents’ scrupulous adherence to the terms of the search warrant, which permitted them to seize the entire “containers/boxes” in which the documents with classification markings were stored, as well as other containers/boxes stored collectively. Moreover, the former President has not established irreparable injury in the deprivation of his personal property.

B. Plaintiff Is Not Entitled to Injunctive Relief

To the extent Plaintiff seeks a preliminary injunction prohibiting the government from continuing to review seized materials while the Court considers his motion, see D.E. 1 at 14–15, such relief is wholly unwarranted.