In the Trump case, a newly unsealed filing said the former president’s lawyers had turned over four additional documents with classification markings that were found in December 2022, four months after the FBI raid at the property.

US District Judge Beryl Howell, an Obama appointee, wrote in the March 2023 opinion: “Notably, no excuse is provided as to how the former president could miss the classified-marked documents found in his own bedroom at Mar-a-Lago.”