Justice Motion for Stay Pending Appeal

https://storage.courtlistener.com/recap/gov.uscourts.flsd.618763/gov.uscourts.flsd.618763.69.0_1.pdf

Specifically, the government seeks a stay to the extent the Order (1) enjoins the further review and use for criminal investigative purpose of records bearing classification markings...

Although the government respectfully disagrees with the Court’s injunction as to a
much broader set of seized materials already in the possession of the investigative team, it is
not at this time seeking a stay as to the vast majority of those materials.

So the gravaman of the motion is classified docs, not everything. The gov't is cutting the baby in two, but at a critical junction, probably to increase the likelihood of success on appeal.

Instead, this motion is limited to the Order’s directives with respect to the seized classified records1 because those aspects of the Order will cause the most immediate and serious harms to the government and the public. The classified records—a discrete set of just over 100 documents—have already been segregated from the other seized records and are being maintained separately. ...

They're speaking baby talk for the baby-brained judge. "Is 100 pages okay for baby to review?

...A stay as to that limited set of records is warranted for three reasons.

First, the government is likely to succeed in its appeal of the Order as it applies to
classified records...

Toldja.

Indeed, the government is likely to succeed even under the Court’s own baby reasoning, which focused principally on Plaintiff’s “personal documents.” [citations to Order omitted] Plaintiff does not and could not assert that he owns or has any possessory interest in classified records; that he has any right to have those government records returned to him; or that he can advance any plausible claims of attorney-client privilege as to such records that would bar the government from reviewing or using them. And although this Court suggested that Plaintiff might be able to assert executive privilege as
to some of the seized records, Supreme Court precedent makes clear that any possible
assertion of privilege that Plaintiff might attempt to make over the classified records would be
overcome by the government’s “demonstrated, specific need” for that evidence. [citations omitted]

Second, the government and the public would suffer irreparable harm absent a stay. ...

How so?

...Moreover, the government and the public are irreparably injured when a criminal investigation of matters involving risks to national security is enjoined.

I'm not convinced by their argument on this and the last sentence is tautological.

Third, the partial stay sought here would impose no cognizable harm on Plaintiff.

Is it a good idea to have limited the request for stay to just the classified docs? I have doubts. 100 docs out of 11,000, that concedes, at least for the purposes of this intermediate step, the shocking judicial encroachment onto executive power of 99.1% of the documents seized by judicially-approved search warrant. That is an awful precedent. They must have a real warranted fear that the 11th Circuit would not reverse Loose Cannon entirely.

...
...On August 8, 2022, the government executed a search warrant at the premises of Plaintiff former President Donald J. Trump based on a judicial finding of probable cause that the search would uncover evidence of violations of 18 U.S.C. §§ 793 (willful retention of national defense information), [Not transmittal] 2071 (concealment or removal of government records), and 1519 (obstruction of a federal investigation).
...
... the government’s upcoming filing [Friday, on the special master] will confirm that it plans to make available to Plaintiff copies of all unclassified documents recovered during the search—both personal records and government records—and that the government will return Plaintiff’s personal items that were not commingled with classified records...

So again, they will give 45th copies of 99.1% of the whole, minus only the classified docs. 

                                                        DISCUSSION

I. The Government Is Likely to Succeed on the Merits
    a. The Court Erred by Exercising Its Equitable Jurisdiction to Enjoin the Government’s Use of the Classified Records

Bold in original.

Yeah, no shit. That was so strained. Fyi, a court exercises equitable jurisdiction when it desperately wants to rule for one side but can't find any like "law" to do it.