Donald Trump’s lawyers have filed their 29-page response to the Special Counsel’s Office seeking a protective order against Trump to protect information, witnesses and evidence Trump may learn about through the discovery process.

Instead of hewing to this narrow framework, the government requests the Court restrict all documents produced by the government, regardless of sensitivity, contrary to established law and President Trump’s First Amendment rights. To resolve this issue, President Trump respectfully requests the Court adopt the attached redline which narrows the Proposed Order to shield only genuinely sensitive materials from public view. This more measured approach is consistent with other protective orders entered by this Court in cases concerning the events of January 6, 2021, and appropriately balances the government’s claimed desire to “protect [] highly sensitive categories of material” and “expedite the flow of discovery,” with the rights of President Trump and the public to free speech and an open proceeding.

Additionally, the Proposed Redline addresses several important definitional and procedural issues. The parties have reached agreement on a small number of these revisions, as indicated in the Proposed Redline. We discuss certain additional revisions in Section B, below.

Finally, to the extent the Court overrules President Trump’s objection to restricting the use of non-sensitive documents produced by the government, we attach an alternative redline that removes edits directed to that issue, while retaining all other proposed revisions