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Rh “A party seeking a preliminary injunction must establish that (1) it has a substantial likelihood of success on the merits; (2) irreparable injury will be suffered unless the injunction issues; (3) the threatened injury to the movant outweighs whatever damage the proposed injunction may cause the opposing party; and (4) if issued, the injunction would not be adverse to the public interest.” Vital Pharmaceuticals, Inc. v. Alfieri, 23 F.4th 1282, 1290–91 (11th Cir. 2022) (internal quotations omitted). “A preliminary injunction is an extraordinary and drastic remedy not to be granted unless the movant clearly establishes the burden of persuasion as to the four requisites.” Id. at 1291 (internal quotations omitted).

For the reasons discussed below, the former President has not established a likelihood of success on the merits. As to the second condition for injunctive relief, the former President has failed to establish that he would suffer any injury absent an injunction—let alone an irreparable injury. First, any Presidential records seized pursuant to the search warrant belong to the United States, not to the former President. 44 U.S.C. § 2202. As such, the former President cannot claim that he is personally injured by a review of those records by personnel within the Executive Branch. See also Nixon v. Administrator of General Services, 433 U.S. 425, 451 (1977) (“Nixon v. GSA”) (review of Presidential records by “personnel in the Executive Branch sensitive to executive concerns” “constitutes a very limited intrusion” into confidentiality of former President’s records). Second, even if review of these materials by personnel within the Executive Branch constituted an injury to the former President, that injury would already be complete. As described above, personnel within the Case Team have already reviewed all of the seized materials except those withheld pursuant to the filter protocol. See supra at 3, 13. Moreover, as the government notified the Court yesterday, DOJ and the Office of the Director of National Intelligence (“ODNI”) are currently facilitating a