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Rh order on April 12 or April 13, 2018. Then-President Trump himself moved to intervene in the proceedings on April 15, 2018—just six days after the search. The need for promptness when a party seeks appointment of a special master is obvious: the government may begin reviewing materials as soon as they are seized, and a delay of even two weeks may well mean—as it does here—that the government has reviewed all of the seized materials by the time relief is sought. The former President’s delay in filing this motion thus strongly “militates against a finding of irreparable harm.” Wreal, 840 F.3d at 1248.

As to the third requisite for injunctive relief, “the threatened injury to the movant” is far outweighed by the “damage the proposed injunction may cause” to the government. Vital Pharmaceuticals, 23 F.4th at 1291 (internal quotations omitted). DOJ is in the midst of an ongoing criminal investigation pertaining to potential violations of the Espionage Act, 18 U.S.C. § 793(e), as well as obstruction of justice, 18 U.S.C. § 1519, and unlawful concealment or removal of government records, 18 U.S.C. § 2071. The Intelligence Community is also reviewing the seized documents to assess the potential risk to national security that would result if these materials were disclosed while they were unlawfully stored at the Premises. An injunction barring any further review of these documents would therefore not only hinder an ongoing criminal investigation, but would also thwart entirely an ongoing and sensitive