61. On June 8, 2022, DOJ COUNSEL sent FPOTUS COUNSEL 1 a letter, which
reiterated that the PREMISES are not autho1ized to store classified info1mation and requested the
preservation of the STORAGE ROOM and boxes that had been moved from the White House to
the PREMISES. Specifically, the letter stated in relevant part:
As I previously indicated to you, Mar-a-Lago does not include a secure location
authorized for the storage of classified information. As such, it appears that since the time
classified documents were removed from the secure facilities at the White House and moved to Mar-a-Lago on or around Januaiy 20, 2021, they have not been handled in an appropriate manner or stored in an appropriate location. Accordingly, we ask that the room at Mar-a-Lago where the
documents had been stored be secured and that all of the boxes that were moved from the
White House to Mar-a-Lago (along with any other items in that room) be preserved in that
room in their current condition until further notice.
2 18 U.S.C. § 793(e) does not use the term "classified information.'' but rather criminalizes the unlawful retention of
"information relating to the national defense." The statute does not define "information related to the national
defense." but courts have construed it broadly. See Gorin v United States. 312 U.S. 19. 28 (1941) (holding that the
phrase "information relating to the national defense" as used in the Espionage Act is a "generic concept of broad
connotations. referring to the military and naval establishments and the related activities of national preparedness").In addition the information must be "closely held" by the U.S. government. See United States v Morison. 844 F.2d 1057, 1071-72 (4th Cir.)1988) F.3d 542, 579 (4th Cir. 2000) (''[I]nformation made public by the government as well as information never protected
by the government is not national defense information."); United States, .. Morison. 844 F.2d 1057, 1071-72 (4th Cir.
1988). Certain courts have also held that the disclosure of the documents must be potentially damaging to to the United States. See Morison, 844 F.2d at 1071-72.
On June 9, 2022, FPOTUS COUNSEL 1 sent an email to DOJ COUNSEL stating, ''I write to
acknowledge receipt of this letter."
[The next two lines of paragraph 61, all of paragraphs 62 through 69 are redacted. I am now up to page 26 of 38 and am breaking.]