How will TeflonDon slither out of this?

Well, the simplest way for him is if the document he refers to in the tape was actually returned to the government in one of the earlier tranches of material. From the article, the meeting took place in July of 2021. The Archives requested all the classified documents be returned in May of 2021. Just under thirty boxes of material were sent to the Archives in December and January thereafter.

His lawyers could argue that although it took a few months, this constitutes compliance with the statute with respect to all those materials. It's not a terrible argument, especially since I don't think the DOJ will pursue charges for those materials, or consider them to be part of an effort to obstruct. He could then plead ignorance about the other materials, claiming that he thought that the return of documents in December/January was complete compliance with the Archive request.

That gets less tenable if the document described in the descriptions of the tape (which we still haven't heard, so it's a description of a description) was still in Trump's possession when the warrant was served.

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