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Rh continuing its review of these materials, both for purposes of its criminal investigation and to assess potential national security risks caused by improper storage of classified records. Appointment of a special master would undoubtedly delay both processes—including because a special master would likely need to obtain a security clearance and specific authorization from relevant entities within the Intelligence Community to review particularly sensitive materials.

Third, appointment of a special master for purposes of reviewing executive privilege claims is not necessary to protect any personal rights belonging to the former President. Unlike possible assertions of attorney-client privilege by the former President with respect to his personal counsel, which is a personal right that belongs to the client, see, e.g., In re Special September 1978 Grand Jury (II), 640 F.2d 49, 62 (7th Cir. 1980), executive privilege exists not “for the benefit of the President as an individual, but for the benefit of the Republic,” Nixon v. GSA, 433 U.S. at 449. In any event, as discussed above, the investigative team has already reviewed all of the seized materials that were not segregated by the filter team. Restricting further review by the government—including by the Intelligence Community—would therefore do little to protect Plaintiff’s purported interests or rights.

This Case Does Not Involve the Search of an Attorney’s Office and the Attorney-Client Privilege Issues Presented Are Not Complex, Voluminous, or Novel

The appointment of a special master is not necessary to adjudicate potential attorney-client privilege issues. “[I]t is well-established that filter teams—also called ‘taint teams’—are routinely employed to conduct privilege reviews.” ''In re Sealed Search Warrant & Application for a Warrant by Tel. or Other Reliable Elec. Means, No. 20-MJ-3278, 2020 WL 6689045, at *2 (S.D. Fla. Nov. 2, 2020) (citing multiple Eleventh Circuit cases approving the use of filter teams), aff’d'', 11 F.4th 1235 (11th Cir. 2021). Tellingly, the cases relied upon by the former President