Trump’s 91 Felony Charges

SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK - against DONALD J. TRUMP, Defendant

THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows:

1. The defendant, in the County of New York and elsewhere, on or about February 14, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated February 14, 2017, marked as a record of the Donald J. Trump Revocable Trust, and kept and maintained by the Trump Organization.

2. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about February 14, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for the Donald J. Trump Revocable Trust, bearing voucher number 842457, and kept and maintained by the Trump Organization.

3. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about February 14, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for the Donald J. Trump Revocable Trust, bearing voucher number 842460, and kept and maintained by the Trump Organization.

4. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about February 14, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump Revocable Trust Account check and check stub dated February 14, 2017, bearing check number 000138, and kept and maintained by the Trump Organization.

5. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about March 16, 2017 through March 17, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated February 16, 2017 and transmitted on or about March 16, 2017, marked as a record of the Donald J. Trump Revocable Trust, and kept and maintained by the Trump Organization.

6. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about March 17, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for the Donald J. Trump Revocable Trust, bearing voucher number 846907, and kept and maintained by the Trump Organization.

7. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about March 17, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump Revocable Trust Account check and check stub dated March 17, 2017, bearing check number 000147, and kept and maintained by the Trump Organization.

8. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about April 13, 2017 through June 19, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated April 13, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

9. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about June 19, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 858770, and kept and maintained by the Trump Organization.

10. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about June 19, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated June 19, 2017, bearing check number 002740, and kept and maintained by the Trump Organization.

11. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about May 22, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated May 22, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

12. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about May 22, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 855331, and kept and maintained by the Trump Organization.

13. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about May 23, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated May 23, 2017, bearing check number 002700, and kept and maintained by the Trump Organization.

14. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about June 16, 2017 through June 19, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated June 16, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

15. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about June 19, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 858772, and kept and maintained by the Trump Organization.

16. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about June 19, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated June 19, 2017, bearing check number 002741, and kept and maintained by the Trump Organization.

17. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about July 11, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated July 11, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

18. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about July 11, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 861096, and kept and maintained by the Trump Organization.

19. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about July 11, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated July 11, 2017, bearing check number 002781, and kept and maintained by the Trump Organization.

20. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about August 1, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated August 1, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

21. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about August 1, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 863641, and kept and maintained by the Trump Organization.

22. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about August 1, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated August 1, 2017, bearing check number 002821, and kept and maintained by the Trump Organization.

23. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about September 11, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated September 11, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

24. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about September 11, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 868174, and kept and maintained by the Trump Organization.

25. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about September 12, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated September 12, 2017, bearing check number 002908, and kept and maintained by the Trump Organization.

26. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about October 18, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated October 18, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

27. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about October 18, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 872654, and kept and maintained by the Trump Organization.

28. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about October 18, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated October 18, 2017, bearing check number 002944, and kept and maintained by the Trump Organization.

29. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about November 20, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated November 20, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

30. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about November 20, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 876511, and kept and maintained by the Trump Organization.

31. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about November 21, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated November 21, 2017, bearing check number 002980, and kept and maintained by the Trump Organization.

32. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about December 1, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an invoice from Michael Cohen dated December 1, 2017, marked as a record of Donald J. Trump, and kept and maintained by the Trump Organization.

33. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about December 1, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, an entry in the Detail General Ledger for Donald J. Trump, bearing voucher number 877785, and kept and maintained by the Trump Organization.

34. AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The defendant, in the County of New York and elsewhere, on or about December 5, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof, made and caused a false entry in the business records of an enterprise, to wit, a Donald J. Trump account check and check stub dated December 5, 2017, bearing check number 003006, and kept and maintained by the Trump Organization.

THE STATE OF GEORGIA v. DONALD JOHN TRUMP, Defendant.

Counts 1, 5, 9, 11, 13, 15, 17, 19, 27-—29, 38-39

1. VIOLATION OF THE GEORGIA RICO (RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS) ACT, O.C.G.A. § 16—-14—-4(c)

5. SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4—-7 & 16—-10—-1

9. CONSPIRACY TO COMMIT IMPERSONATING A PUBLIC OFFICER, O.C.G.A. §§ 16—-4-8 & 16-10-23

11. CONSPIRACY To COMMIT FORGERY 1N THE FIRST DEGREE, O.C.G.A. §§ 16-4—-8 & 16-9-1(b)

13. CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16—-4—-8 & 16—-10—-20

15. CONSPIRACY TO COMMIT FILING FALSE DOCUMENTS, O.C.G.A. §§ 16-—4—-1 & 16—-10-—20.1(b)(1)

17. CONSPIRACY TO COMMIT FORGERY IN THE FIRST DEGREE, O.C.G.A. §§ 16-4—-8 & 16-—9-—1(b)

19. CONSPIRACY TO COMMIT FALSE STATEMENTS AND WRITINGS, O.C.G.A. §§ 16-4-8 & 16-10-20

27. FILING FALSE DOCUMENTS, O.C.G.A. § 16-10—-20.1(b)(1)

28. SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER O.C.G.A. §§ 16—-4-7 & 16-10-1

29. FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10-20

38. SOLICITATION OF VIOLATION OF OATH BY PUBLIC OFFICER, O.C.G.A. §§ 16-4—-7 & 16—-10-—1

39. FALSE STATEMENTS AND WRITINGS, O.C.G.A. § 16-10—-20

UNITED STATES OF AMERICA v. DONALD J . TRUMP, Defendant.

The Grand Jury charges that, at all times material to this Indictment, on or about the dates and at the approximate times stated below:

1. Conspiracy to Defraud the United States—18 U.S.C. § 371: From on or about November 14, 2020, through on or about January 20, 2021, in the District of Columbia and elsewhere, the Defendant, DONALD J. TRUMP, did knowingly combine, conspire, confederate, and agree with co-conspirators, known and unknown to the Grand Jury, to defraud the United States by using dishonesty, fraud, and deceit to impair, obstruct, and defeat the lawful federal government function by which the results of the presidential election are collected, counted, and certified by the federal government.

2. Conspiracy to Obstruct an Official Proceeding—18 U.S.C. § 1512(k)): The allegations contained in paragraphs 1 through 4 and 8 through 123 of this Indictment are re-alleged and fully incorporated here by reference. From on or about November 14, 2020, through on or about January 7, 2021, in the District of Columbia and elsewhere, the Defendant, DONALD J. TRUMP, did knowingly combine, conspire, confederate, and agree with co-conspirators, known and unknown to the Grand Jury, to corruptly obstruct and impede an official proceeding, that is, the certification of the electoral vote, in violation of Title 18, United States Code, Section 1512(c)(2). (In violation of Title 18, United States Code, Section 1512(k))

3. Obstruction of, and Attempt to Obstruct, an Official Proceeding—18 U.S.C. §§ 1512(c)(2), 2): The allegations contained in paragraphs 1 through 4 and 8 through 123 of this Indictment are re-alleged and fully incorporated here by reference. From on or about November 14, 2020, through on or about January 7, 2021, in the District of Columbia and elsewhere, the Defendant, DONALD J. TRUMP, attempted to, and did, corruptly obstruct and impede an official proceeding, that is, the certification of the electoral vote. (In violation of Title 18, United States Code, Sections 1512(c)(2), 2)

4. Conspiracy Against Rights—18 U.S.C. § 241): The allegations contained in paragraphs 1 through 4 and 8 through 123 of this Indictment are re-alleged and fully incorporated here by reference. From on or about November 14, 2020, through on or about January 20, 2021, in the District of Columbia and elsewhere, the Defendant, DONALD J . TRUMP, did knowingly combine, conspire, confederate, and agree with co-conspirators, known and unknown to the Grand Jury, to injure, oppress, threaten, and intimidate one or more persons in the free exercise and enjoyment of a right and privilege secured to them by the Constitution and laws of the United States—that is, the right to vote, and to have one's vote counted. (In violation of Title 18, United States Code, Section 241)

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Willful Retention of National Defense Information (18 U.S.C. § 793(e))):

1. TOP SECRET//NOFORN//SPECIAL HANDLING: Document dated May 3, 2018, concerning White House intelligence briefing related to various foreign countries

2. TOP SECRET//SI//NOFORN//SPECIAL HANDLING: Document dated May 9, 2018, concerning White House intelligence briefing related to various foreign countries

3. TOP SECRET//SJ//NOFORN//FISA: Undated document concerning military capabilities of a fore ign country and the United States, with handwritten annotation in black marker

4. TOP SECRET//SPECIAL HANDLING: Document dated May 6. 2019, concerning White House intelligence briefing related to foreign countries, including military activities and planning of foreign countries

5. TOP SECRET//[redacted]/[redacted]//ORCON/NOFORN: Document dated June 2020 concerning nuclear capabilities of a foreign country

6. TOP SECRET//SPECIAL HANDLING: Document dated June 4, 2020, concerning White House intelligence briefing related to various foreign countries

7. SECRET//NOFORN: Document dated October 21, 2018, concerning communications with a leader of a foreign country

8. SECRET//REL TO USA, FVEY: Document dated October 4, 2019, concerning military capabilities of a foreign country

9. TOP SECRET//[redacted]/[ redacted)//ORCON/NOFORN/FISA: Undated document concerning military attacks by a foreign country

10. TOP SECRET//TK//NOFORN: Document dated November 2017 concerning military capabilities of a foreign country

11. SECRET//REL TO USA, FVEY: Pages of undated document concerning projected regional military capabilities of a foreign country and the United States

12. SECRET//REL TO USA, FVEY: Pages of undated document concerning projected regional military capabilities of a foreign country and the United States

13. TOP SECRET//SJ/fK//NOFORN: Undated document concerning military capabilities of a foreign country and the United States

14. SECRET//ORCON/NOFORN: Document dated January 2020 concerning military options of a foreign country and potential effects on United States interests

15. SECRETllORCON/NOFORN: Document dated February 2020 concerning policies in a fore ign country

16. SECRET//ORCON/NOFORN: Document dated December 2019 concerning foreign country support of terrorist acts against United States interests

17. TOP SECRET//[redacted]/TK//ORCON/IMCON/NOFORN: Document dated January 2020 concerning military capabilities of a foreign country

18. SECRET//NOFORN: Document dated March 2020 concerning military operations against United States forces and others

19. SECRET//FORMERLY RESTRICTED DATA: Undated document concerning nuclear weaponry of the United States

20. TOP SECRET//(redacted]//ORCON/NOFORN: Undated document concerning tirneline and details of attack in a foreign country

21. SECRET//NOFORN: Undated document concerning military capabilities of foreign countries

22. TOP SECRET//[redacted]//RSEN/ORCON/NOFORN: Document dated August 2019 concerning regional military activity of a foreign country

23. TOP SECRET//SPECIAL HANDLING: Document dated August 30, 2019, concerning White House intelligence briefing related to various fore ign countries, with handwritten annotation in black marker

24. TOP SECRET//HCS-P/S1//ORCON-USGOV/NOFORN: Undated document concerning military activity of a foreign country

25. TOP SECRET//HCS-P/SV/ORCON-USGOV/NOFORN: Document dated October 24, 2019, concerning military activity of foreign countries and the United States

26. TOP SECRET//[redacted]//ORCON/NOFORN/FISA: Document dated November 7, 2019, concerning military activity of foreign countries and the United States

27. TOP SECRET//S1/fK//NOFORN: Document dated November 2019 concerning military activity of foreign countries

28. TOP SECRET//SPECIAL HANDLING: Document dated October 18, 2019, concerning White House intelligence briefing related to various foreign co untries

29. TOP SECRET//[redacted]/Sl/fK//ORCON/NOFORN: Document dated October 18, 2019, concerning military capabilities of a foreign country

30. TOP SECRET//[redacted]//ORCON/NOFORN/FJSA: Document dated October 15, 2019, concerning military activity in a foreign country

31. TOP SECRET//SJ/TK//NOFORN: Document dated February 2017 concerning military activity of a foreign country

32. TOPSECRET//NOFORN: Presentation concerning military activity in a foreign country

All in violation of Title 18, United States Code, Section 793(e)

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Conspiracy to Obstruct Justice (18 U.S.C. § l5l2(k))):

33. The General Allegations of this Superseding Indictment are re-alleged and fully incorporated here by reference. From on or about May 11 , 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA did knowingly combine, conspire, confederate, and agree with each other and with others known and unknown to the grand jury, to engage in misleading conduct toward another person and corruptly persuade another person to withhold a record, document, and other object from an official proceeding, in violation of 18 U.S.C. § I 512(b)(2)(A) ; to corruptly persuade another person, with intent to cause and induce any person to alter, destroy, mutilate, and conceal an object with intent to impair the object's integrity and availability for use in an official proceeding, in violation of 18 U.S.C. § l 5 l 2(b)(2)(8); and to corruptly alter, destroy, mutilate, and conceal a record, document, and other object from an official proceeding, in violation of 18 U.S.C. § 1512(c)(l).

All in violation of Title 18, United States Code, Section 1512(k).

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Withholding a Document or Record (18 U.S.C. §§ 1512(b)(2)(A), 2)):

34. The General Allegations of this Superseding Indictment are re-alleged and fully incorporated here by reference. From on or about May 11 , 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, DONALD J. TRUMP and WALTINE NAUTA, did knowingly engage in misleading conduct toward another person, and knowingly corruptly persuade and attempt to persuade another person, with intent to cause and induce any person to withhold a record, document, and other object from an official proceeding; that is--(1) TRUMP attempted to persuade Trump Attorney 1 to hide and conceal documents from a federal grand jury; and (2) TRUMP and NAUTA misled Trump Attorney I by moving boxes that contained documents with classification markings so that Trump Attorney I would not find the documents and produce them to a federal grand jury.

All in violation ofTitle 18, United States Code, Sections 1512(b)(2)(A) and 2.

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Corruptly Concealing a Document or Record (18 U.S.C. §§ 1512(c)(l), 2)):

35. The General Allegations of th is Superseding Indictment are re-alleged and fully incorporated here by reference. From on or abo ut May 11 , 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, DONALD J. TRUMP and WALTINE NAUTA, did corruptly conceal a record, document, and other object, and attempted to do so, with the intent to impair the object's integrity and availability for use in an official proceeding; that is- TRUMP and NAUTA hid and concealed boxes that contained documents with classification markings from Trump Attorney I so that Trump Attorney 1 would not find the documents and produce them to a federal grand jury.

All in violation of Title 18, United States Code, Sections 1512(c)(1) and 2.

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Concealing a Document in a Federal Investigation (18 u.s.c. §§ 1519, 2)):

36. The General Allegations of this Superseding Indictment are re-alleged and fully incorporated here by reference. rom on or about May 11, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, DONALD J. TRUMP and WALTINE NAUTA, did knowingly conceal, cover up, falsify, and make a false entry in any record, document, and tangible object with the intent to impede, obstruct, and influence the investigation and proper administration of any matter within the jurisdiction of a department and agency of the United States, and in relation to and contemplation of any such matter; that is--<luring a federal criminal investigation being conducted by the FBI, (I) TRUMP and NAUT A hid, concealed, and covered up from the FBI TRUMP's continued possession of documents with classification markings at The Mar-a-Lago Club; and (2) TRUMP caused a false certification to be submitted to the FBI.

All in violation of Title 18, United States Code, Sections 1519 and 2.

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Scheme to Conceal (18 U.S.C. §§ 1001(a)(1), 2)):

37. The General Allegations of this Supersed ing Indictment are re-alleged and fully incorporated here by reference. From on or about May 11 , 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, DONALD J. TRUMP and WALTINE NAUTA, in a matter within the jurisdiction of the judicial branch and executive branch of the United States government, did knowingly and willfully falsify, conceal, and cover up by any trick, scheme, and device a material fact; that is-during a federal grand jury investigation and a federal criminal investigation being conducted by the FBI, TRUMP and NAUTA hid and concealed from the grand jury and the FBI TRUMP's continued possession of documents with classification markings.

All in violation of Title 18, United States Code, Sections I 00 1(a)(l) and 2.

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (False Statements and Representations (18 U.S.C. §§ 1001(a)(2), 2)):

38. The General Allegations of this Superseding Indictment are re-alleged and fully incorporated here by reference. On or about June 3, 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant, DONALD J. TRUMP, in a matter within the jurisdiction of the judicial branch and executive branch of the United States government, did knowingly and willfully make and cause to be made a materially false, fictitious, and fraudulent statement and representation; that is-during a federal grand jury investigation and a federal criminal investigation being conducted by the FBI, TRUMP caused the follow ing false statements and representations to be made to the grand jury and the FBI in a sworn certification executed by Trump Attorney 3: a."A diligent search was conducted of the boxes that were moved from the White House to Florida"; b."This search was conducted after receipt of the subpoena, in order to locate any and all documents that are responsive to the subpoena"; and c."Any and all responsive documents accompany this certification." The statements and representations set forth above were false, as TRUMP knew, because TRUMP had directed that boxes be removed from the Storage Room before Trump Attorney l conducted the June 2, 2022 search for documents with classification markings, so that Trump Attorney 1's search would not and did not include all of TRUMP's boxes that were removed from the White House; Trump Attorney 1's search would not and did not locate all documents responsive to the May l l Subpoena; and all responsive documents were not provided to the FBI and the grand jury with the certification. In fact, after June 3, 2022, more than 100 documents with classification markings remained at The Mar-a-Lago Club until the FBI search on August 8, 2022.

All in violation of Title 18, United States Code, Sections 1001(a)(2) and 2.

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Altering, Destroying, Mutilating, or Concealing an Object (18 U.S.C. §§ 1512(b)(2)(B), 2)):

40. The General Allegations of this Superseding Indictment are re-alleged and fully incorporated here by reference. From on or about June 22, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA did knowingly corruptly persuade and attempt to persuade another person, with intent to cause and induce any person to alter, destroy, mutilate, and conceal an object with intent to impair the object's integrity and avai lability for use in an official proceeding; that is-TRUMP, NAUT A, and DE OLIVEIRA requested that Trump Employee 4 delete security camera footage at The Mar­ a-Lago Club to prevent the footage from being provided to a federal grand jury.

All in violation of Title 18, United States Code, Sections 1512(b)(2)(8) and 2.

UNITED STATES OF AMERICA v. DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA, Defendants. (SUPERSEDING INDICTMENT)

At times material to this Superseding Indictment, on or about the dates and approximate times stated below (Corruptly Altering, Destroying, Mutilating or Concealing a Document, Record, or Other Object (18 U.S.C. §§ 1512(c)(1), 2)):

41. The General Allegations of this Superseding Indictment are re-alleged and fully incorporated here by reference. From on or about June 22, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, DONALD J. TRUMP, WALTINE NAUTA, and CARLOS DE OLIVEIRA did corruptly alter, destroy, mutilate. and conceal a record, document and other object and attempted to do so, with the intent to impair the object's integrity and availability for use in an official proceeding; that is- TRUMP, NAUTA, and DE OLIVEIRA requested that Trump Employee 4 delete security camera footage at The Mar-a-Lago Club to prevent the footage from being provided to a federal grand jury.

All in violation of Title 18, United States Code, Sections 1512(c)(1) and 2.