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Rh the possibility of review in the highly unusual circumstances presented here would materially chill communications by future presidential advisers. See 418 U.S. at 712 (presidential advisors would not likely “be moved to temper the candor of their remarks by the infrequent occasions of disclosure because of the possibility that such conversations will be called for in the context of a criminal prosecution”). To the contrary, the Executive Branch’s efforts here are designed to ensure the confidentiality and proper treatment of sensitive presidential records that were improperly stored—a process that should enhance, rather than undermine, future presidential communications.

The Executive Branch’s review here also serves another compelling interest that was not at issue in Nixon: The records at issue include sensitive and highly classified documents. As the government has explained, the Intelligence Community, under the supervision of the Director of National Intelligence, is conducting a classification review of those documents and an assessment of the potential risk to national security that could result from their disclosure. D.E. 31 at 2–3. That additional vital purpose provides yet further reason to conclude that the Executive Branch’s interest in securing and reviewing the materials at issue here outweighs any limited burden on the confidentiality of presidential communications—and thus that the privilege would be overcome even if it were validly asserted. This Court should be particularly reluctant to order disclosure of highly classified materials to a special master absent an especially strong showing that such a step is necessary. Cf. United States v. Reynolds, 345 U.S. 1, 10–11 (1952) (courts should be cautious before requiring judicial review, even ex parte and in camera, of documents whose disclosure would jeopardize national