If his lawyers alleged it in a court filing then yes, they’d best have an argument to back it up. On the other hand if it’s about Trump saying they could have done so in a tween on truth social then that’s not an allegation before the special master and him asking about is potentially sort of ominous (I.e. he’s fishing for reasons to discredit Trump rather than just selerating out the material seized beyond the scope of the warrant).
NBC’s narrative juxtaposes unconnected things to lead the reader to assume they are connected. NBC never actually states that the Judge ordered certain filings in response to Trump’s media comments or anything else. They just want us to read that into it.
I think the judge knows that Trumps loves to lob grenades via media, and he’s wise to provide an opportunity for Trump to put any allegations on the record. If he has no basis, he should shut up.