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Case 9:23-cr-80101-AMC Document 566 Entered on FLSD Docket 05/21/2024 Page 19 of 28
aggressive position in the opening submission, they agreed to “seek[] only Per. 18’s fact work
product.” Id.
Following a March 9, 2023, hearing attended by the Special Counsel’s Office and counsel
for President Trump and Per. 18, Judge Howell granted, in part, and denied, in part, the motion.
Ex. 17. The court ordered Per. 18 to produce documents “reflecting his efforts to comply” with
the Trump Office Subpoena, and that “may have informed his knowledge” of the Trump
Organization Subpoena. Judge Howell also required Per. 18 to produce the May 2022
Recording and the June 2022 Recording, based on reasoning set forth in separate orders. Exs. 18,
19. On March 22, 2023, the D.C. Circuit denied motions by President Trump and Per. 18 to stay
Judge Howell’s rulings. See Order, In re Sealed Case, Nos. 23-3035, 23-3036 (D.C. Cir. Mar. 22,
7. The Compelled Testimony
On March 24, 2023, the Special Counsel’s Office required Per. 18 and to testify
before a grand jury in the District of Columbia—despite the lack of venue for any of the offenses
under consideration. The prosecutors questioned Per. 18 extensively regarding, inter alia, the
otherwise-privileged communications with President Trump, the May 2022 Recording, and the
June 2022 Recording.
B. Applicable Law
1. Attorney-Client Privilege And Work Product
“Traditionally, the attorney-client privilege, like the privilege extending to attorney work
product, is sacrosanct.” United States v. Stein, 2023 WL 2585033, at *2 (S.D. Fla. 2023) (cleaned
up). “The attorney-client privilege attaches, of course, to confidential communications between
an attorney and client for the purposes of securing legal advice or assistance.” Drummond Co.,

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