The ruling by the judge, Aileen M. Cannon, was her latest effort in the past several months to keep the public from seeing Mr. Smith’s sprawling report — one of the most significant parts of his twin prosecutions of Mr. Trump that has yet to see the light of the day.
The order, issued from Federal District Court in Fort Pierce, Fla., slammed Mr. Smith for the “brazen stratagem” of drafting his report even after Judge Cannon had dismissed the classified documents case in July 2024 and found that he had been improperly appointed to his post as special counsel.
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