On Thursday, the judge in his case - which deals with Trump's efforts to overturn the election - reminded Trump it is a crime to intimidate a juror, bribe anyone or obstruct the administration of justice.
Asked if he understood the standard disclaimer, Trump responded that he did.
Yet on Friday, Trump posted a threat against those involved in the case, leading Smith to fear that Trump could use the discovery material against those involved.
Smith said the proposed protective order was not 'overly restrictive,' noting that it would still enable Trump to use discovery materials in his defense.
'All the proposed order seeks to prevent is the improper dissemination or use of discovery materials, including to the public,' Smith wrote.
'Such a restriction is particularly important in this case because the defendant has previously issued public statements on social media regarding witnesses, judges, attorneys and others associated with legal matters pending against him.
'And in recent days, regarding this case, the defendant has issued multiple posts - either specifically or by implication - including the following, which the defendant posted just hours ago.'
Smith then included a screenshot of the Truth Social post.
A Trump spokesperson said the post was 'political speech' and dismissed claims that it was threatening.
'The Truth post cited is the definition of political speech and was in response to the RINO, China-loving, dishonest special interest groups and Super PACs, like the ones funded by the Koch Brothers and the Club for No Growth,' they said.
https://www.dailymail.co.uk/news/article-12375335/Trump-special-counsel-Jack-Smith-enters-ex-presidents-threatening-Truth-Social-post-saying-Im-coming-evidence-just-HOURS-published.html