Listen to the Indictment

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The following is a reading of the Trump classified documents indictment. Part of the text have been edited for clarity and ease of listening. United States of America versus Donald j Trump and Walt Nada. Introdu, one, defendant Donald j Trump was the forty fifth president of the United States of America. He held office from January twentieth twenty seventeen until January twentieth twenty twenty one.

As president, Trump had lawful access to the most sensitive classified documents and national defense information gathered and owned by the United States government. Including information from the agencies that comprise the United States intelligence community and the United States Department of Defense. Two, Over the course of his presidency, Trump gathered newspapers, press clippings, letters, notes, cards, photographs, official documents, and other materials in cardboard boxes that he kept in the White House. Among the materials Trump stored in his boxes were hundreds of classified documents. Three.

The classified documents Trump stored in his boxes included information regarding defense and weapons capabilities of both the United States and foreign countries. United States nuclear programs, potential vulnerabilities of the United States and its allies to military attack, and plans for possible retaliation in response to a foreign attack. The unauthorized disclosure of these classified documents could put at risk the national security of the United States, foreign relations, the safety of the United States military, and human sources, and the continued viability of sensitive intelligence collection methods. Four, At twelve PM on January twentieth twenty twenty one, Trump ceased to be president. As he departed the White House, Trump caused scores of boxes, many of which contained classified documents to be transported to the Mar a Lago club in Palm Beach, Florida.

Where he maintained his residence. Trump was not authorized to possess or retain those classified documents. Five. The Mar a Lago Club was an active social club, which between January twenty twenty one and August twenty twenty two hosted events for tens of thousands of members

and guests. After Trump’s presidency, the Mar

a Lago Club was not an authorized location for the storage, possession, review, display, or discussion of classified documents. Nevertheless, Trump stored his boxes containing classified documents in various locations at the Mar a Lago Club, including in

a ballroom, a bathroom, and shower, an office space, his bedroom, and a storage room. Six, on two occasions in twenty twenty one, Trump showed classified documents to others as follows, a,

In July twenty twenty one at Trump National Golf Club in Bedminster, New Jersey, the Bedminster Club. During an audio recorded meeting with a writer, a publisher, and two members of his staff, none of whom possessed a security clearance, Trump showed and described a plan of attack that Trump said was prepared for him by the Department of Defense and a senior military official. Trump told the individuals that the plan was highly confidential and secret. Trump also said, as president, I could have declassified it, and Now I can’t, you know, but this is still a secret. B.

In August or September twenty twenty one at the Bedminster Club, Trump showed a representative of his political action committee who did not possess a security clearance, a classified map related to a military operation and told the representative that he should not be showing it to the representative and that the representative should not get too close. Seven. On March thirtieth twenty twenty two, the Federal Bureau of Investigation opened a criminal investigation into the unlawful retention of classified documents at the Mar a Lago club. A federal grand jury investigation began the next month. The grand jury issued a subpoena requiring Trump to turn over all documents with classification markings.

Trump endeavored to obstruct the FBI and grand jury investigations and conceal his continued retention of classified documents by, among other things. A, suggesting that his attorney falsely represent to the FBI and grand jury that Trump did not have documents called for by the grand jury subpoena. B, directing defendant Walton NADA to move boxes of documents to conceal them from Trump’s attorney, the FBI, and the grand jury. C, suggesting that his attorney hide or destroy documents called for by the grand jury subpoena. D, Providing to the FBI and grand jury just some of the documents called for by the grand jury subpoena, while claiming that he was cooperating fully.

And e, causing a certification to be submitted to the FBI and grand jury falsely representing that all documents called for by the grand jury subpoena had been produced. While knowing that in fact, not all such documents had been produced. Eight. As a result of Trump’s retention classified documents after his presidency and refusal to return them. Hundreds of classified documents were not recovered by the United States government until twenty twenty two.

As follows. A. On January seventeenth, nearly one year after Trump left office, And after months of demands by the National Archives and Records Administration for Trump to provide all missing presidential records, Trump provided only fifteen boxes which contained one hundred ninety seven documents with classification markings. B. On June third, In response to a grand jury subpoena demanding the production of all documents with classification markings, Trump’s attorney provided to the FBI thirty eight more documents with classification markings.

C. On August eighth, pursuant to a court authorized search warrant, The FBI recovered from Trump’s office and a storage room at the Mar a Lago Club, one hundred two more documents with classification markings.

Trump’s co conspirator, nine. Defendant NADA was

a member of the United States Navy stationed as a valet in the White House during Trump’s presidency. Beginning in August twenty twenty one, NADA became an executive assistant in the office of Donald j Trump and served as Trump’s personal aid or body man. Not a reported to Trump, worked closely with Trump, and traveled with Trump.

The Mar a Lago club. Ten.

The Mar a Lago Club was located on South Ocean Boulevard in Palm Beach, Florida and included Trump’s residence. More than twenty five guest rooms two ball rooms, a spa, a gift store, exercise facilities, office space, and an outdoor pool and patio. As of January twenty twenty one, The Mar a Lago Club had hundreds of members and was staffed by more than one hundred fifty full time, part time, and temporary employees. Eleven. Between January twenty twenty one and August twenty twenty two, the Mar a Lago club hosted more than one hundred fifty social events.

Including weddings, movie premieres, and fundraisers that together drew tens of thousands of guests. Twelve, The United States Secret Service, the Secret Service, provided protection services to Trump and his family after he left office, including at the Mar a Lago Club, but it was not responsible for the protection of Trump’s boxes or their contents. Trump did not inform the secret service that he was storing boxes containing classified documents at the Mar a Lago club. Classified information. Thirteen.

National Security information was information owned by, produced by produced for and under the control of the United States government. Pursuant to executive order one two nine five eight. Signed on April seventeenth nineteen ninety five, as amended by executive order one three two nine two on March twenty fifth two thousand three, An executive order one three five two six on December twenty ninth two thousand nine, national security information was classified as top secret. Secret or confidential as follows. A.

Information was classified as top secret. If the unauthorized disclosure of that information reasonably could be expected to cause exceptionally grave damage to the national security, that the original classification authority was able to identify or describe. B. Information was classified as secret If the unauthorized disclosure of that information reasonably could be expected to cause serious damage to the national security that the original classification authority was able to identify or describe. C.

Information was classified as confidential, If the unauthorized disclosure of that information reasonably could be expected to cause damage to the national security that the original classification authority was to identify or describe. Fourteen. The classification marking no foreign stood for not releasable to foreign nationals. And denoted that dissemination of that information was limited to United States persons. Fifteen.

Classified information related to intelligent sources methods and analytical processes, was designated as sensitive compartmented information, SCI. SCI was to be processed, stored, used, or discussed in an accredited sensitive compartmented information facility, CIF. And only individuals with the appropriate security clearance and additional SCI permissions were authorized to have access to such national security information. Sixteen. When the vulnerability of or threat to, specific classified information was exceptional, and the normal criteria for determining eligibility for access to classified information were insufficient to protect the information from unauthorized disclosure.

The United States could establish special access programs, SAP’s to further protect the classified information. The number of these programs was to be kept to an absolute minimum and limited to programs in which the number of persons who ordinarily would have access would be reasonably small and commensurate. With the objective of providing enhanced protection for the information involved. Only individuals with the appropriate security clearance and additional SAP permissions were authorized to have access to such national security information, which was subject to enhanced handling and storage requirements. Seventeen.

Pursuant to executive order one three five two six. Information classified at any level could be lawfully assessed only by persons determined by an appropriate United States government official to be eligible for access to classified information and who had signed an approved non disclosure agreement, who received a security clearance, and who had a need to know the classified information. After his presidency, Trump was not authorized to possess or retain classified documents. Eighteen. Executive order one three five two six provided that a former president could obtain a waiver of the need to know requirement.

If the agency head or senior agent official of the agency that originated the classified information. One, determined in writing that access was consistent with the interest of national security. And two, took appropriate steps to protect classified information from unauthorized disclosure or compromise and ensured that the information was safeguarded in a manner consistent with the order. Trump did not obtain any such waiver after his presidency. The executive branch departments and agencies whose classified documents Trump retained after his presidency.

Nineteen. As part of his official duties as president, Trump received intelligence briefings from high level United States government officials. Including briefings from the director of the central intelligence agency, the chairman of the joint chiefs of staff, senior White House officials, and a designated briefer. He regularly received a collection of classified intelligence from the United States intelligence community, USIC, known as the president’s daily brief. Twenty.

The USIC’s mission was to collect, analyze, and deliver foreign intelligence and counter intelligence information to America’s leaders, including the president, policymakers, law enforcement, and the military. So they could make sound decisions to protect the United States. The USIC consisted of United States executive branch departments and agencies responsible for the conduct of foreign relations and the protection of national security. Twenty one, After his presidency, Trump retained classified documents originated by or implicating the equities of multiple USIC member and other executive branch departments and agencies. Trump’s public statements on classified information.

Twenty two, As a candidate for President of the United States, Trump made the following public statements among others about classified information. A. On August eighteenth twenty sixteen, Trump stated, in my administration, I’m going to enforce all laws concerning the protection of classified information. No one will be above the law. B.

On September sixth twenty sixteen, Trump stated We also need to fight this battle by collecting intelligence and then protecting protecting our classified secrets. We can’t have someone in the Oval Office who doesn’t understand the meaning of the word confidential or classified. C. On September seventh, twenty sixteen. Trump stated, one of the first things we must do is to enforce all classification rules and to enforce all laws relating to the handling of classified information.

D. On September nineteenth twenty sixteen, Trump stated We also need the best protection of classified information. E. On November third twenty sixteen, Trump stated Service members here in North Carolina have risked their lives to acquire classified intelligence to protect our country. Twenty three.

As president of the United States, on July twenty sixth twenty eighteen, Trump issued the following statement about classified information. As the head of the executive branch and commander in chief, I have a unique constitutional responsibility to protect the nation’s classified information. Including by controlling access to it. More broadly, the issue of a former executive branch official’s security clearance raises larger questions about the practice of former officials maintaining access to our nation’s most sensitive secrets long after their time in government has ended. Such access is particularly inappropriate when former officials have transitioned into highly partisan positions and seek to use real or perceived access to sensitive information to validate their political attacks.

Any access granted to our nation’s secrets should be in furtherance of national, not personal, interests.

Trump’s retention of classified documents after his presidency. Twenty four.

In January twenty twenty one, as he was preparing to leave the White House. Trump and his White House staff including NADA, packed items, including some of Trump’s boxes. Trump was personally involved in this process. Trump caused his boxes containing hundreds of classified documents to be transported from the White House to

the Mar a Lago club. Twenty five. From January through March fifteenth, twenty twenty one, some of Trump’s boxes were stored in the Mar

a Lago club’s white and gold ballroom in which events and gatherings took place. Trump’s boxes were for a time stacked on the ballroom stage. Twenty six. In March twenty twenty one, NADA and others moved some of Trump’s boxes from the white and gold ballroom to the business center at the Mar a Lago Club. Twenty seven.

On April fifth, twenty twenty one, an employee of the office of Donald j Trump. Trump employee one, texted another employee of that office. Trump employee two, To ask whether Trump’s boxes could be moved out of the business center to make room for staff to use it as an office. Trump employee too replied, Whoa. Okay.

So Potus specifically asked Walt for those boxes to be in the business center because they are his papers. Later that day, Trump employee one and Trump employee two exchanged the following text messages. Trump employee two, We can definitely make it work if we move his papers into the lake room? Trump employee won. There is still a little room in the shower where his other stuff is.

Is it only his papers he cares about? There’s some other stuff in there that are not papers. Could that go to storage? Or does he want everything in there on property? Trump employee too.

Yes. Anything that’s not the beautiful mind paper boxes can definitely go to storage. Wanna take a look at the space and start moving tomorrow AM? Twenty eight. After the text exchange between Trump employee one and Trump employee two, in April twenty twenty one, Some of Trump’s boxes were moved from the business center to a bathroom and shower in the Mar

a Lago club’s Lake room. Twenty nine.

In May twenty twenty one, Trump directed that a storage room on the ground floor of the Mar a Lago Club, the storage room Be cleaned out so that it could be used to store his boxes. The hallway leading to the storage room could be reached from multiple outside entrances including one accessible from the Mar a Lago Club pool patio through a doorway that was often kept open. The storage room was near the liquor supply closet linen room, lockshop, and various other rooms. Thirty. On June twenty fourth twenty twenty one, Trump’s boxes that were in the lake room were moved to the storage room.

After the move, there were more than eighty boxes in the storage room. Thirty one. On December seventh twenty twenty one, NADA found several of Trump’s boxes fallen, and their contents spilled onto the floor of the storage room. Including a document marked secret slash slash r e l to USA f v, which denoted that the information in the doc was releasable only to the five eyes intelligence alliance consisting of Australia, Canada, New Zealand, the United Kingdom, and the United States. Nada texted Trump employee too.

I opened the door and found this. NADA also attached two photographs he took of the spill. Trump employee too replied, oh no no no. And I’m sorry Potus had my phone. Trump’s unlawful retention of this document is charged in count eight of this indictment.

Trump’s disclosures of classified information in private meetings thirty two. In May twenty twenty one, Trump caused some of his boxes to be brought to his summer residence at the Bedminster Club. Like the Mar

a lago club after Trump’s presidency,

the Bedminster club was not an authorized location for the storage, possession, review, display

or discussion of classified documents. Thirty three. On July twenty first, twenty twenty one, when he was

no longer president, Trump gave an interview in his office at the Bedminster Club, to a writer and a publisher in connection with a then forthcoming book. Two members of Trump’s staff also attended the interview, which was recorded with Trump’s knowledge and consent. Before the interview, The media had published reports that at the end of Trump’s term as president, a senior military official, the senior military official, purportedly feared that Trump might order an attack on country a and that the senior military official advised Trump against doing so. Thirty four. Upon greeting the writer, publisher, and his two staff members, Trump stated, look what I found.

This was the senior military officials plan of attack, Reddit, and just show. It’s interesting. Later in the interview, Trump engaged in the following exchange.

Trump. Well, with the senior military official, Let me see that. I’ll show you an example. He said that I wanted to attack country a. Isn’t it amazing?

I have a big pile of papers this thing just came up. Look, this was him. They presented me this. This is off the record but they presented me this. This was him.

This was the defense department and him. Ryder. Wow. Trump. We looked at some.

This was him. This wasn’t done by me. This was him. All sorts of stuff. Pages long.

Look. Stafford. Mhmm. Trump. Wait a minute.

Let’s see here. Stafford. Laffer. Yeah. Trump.

I just found, isn’t that amazing? This totally wins my case, you know? Stafford.

Mhmm. Trump, except it is like, highly confidential, staffer. Yeah, laughter, Trump. Secret. This is secret information.

Look, look at this. You attack and by the way, isn’t that incredible? Stafford. Yeah. Trump.

I was just thinking because we were talking a bow, and you know he said, He wanted to at country a and what audit. Tax staffer. You did. Trump.

This was done by the military and given to me.

I think we can probably write. Stafford. I don’t know. We’ll we’ll have to see. Yeah.

We’ll have to try to Trump. Declassify it. Staffer. Figure out a yeah. Trump.

See as president, I could have declassified it. Stafford. Yeah. Laugh. Trump.

Now I can’t, you know, but this is still a secret. Staff her. Yeah. Laugh. Now we have a problem.

Trump, isn’t that interesting?

At the time of this exchange, the writer, the publisher, and Trump’s two staff members did not have security clearances or any need to know any classified information about a plan of attack on Country a thirty five. In August or September twenty twenty one, when he was no longer president, Trump met in his office at the Bedminster Club with a representative of his political action committee, the PAC representative. During the meeting, Trump commented that an ongoing military operation in country b was not going well. Trump showed the PI representative a classified map of country b and told the PC representative that he should not be showing the map to the PC representative and to not get too close. The PC representative did not have a security clearance or any need to know classified information about the military operation.

Thirty six. On February sixteenth twenty seventeen, four years before Trump’s disclosures of classified information set forth above, Trump said at a press conference, the first thing I thought of when I heard about it is how does the press get this information that’s classified? How do they do it? You know why? Because it’s an illegal process and the press should be ashamed of themselves.

But more importantly, the people that gave out the information to the press should be ashamed of themselves. Really ashamed. Trump’s production of fifteen cardboard boxes to the National Archives and Records Administration. Thirty seven. Beginning in May twenty twenty one, the National Archives and Records Administration Nara, which was responsible for archiving presidential records.

Repeatedly demanded that Trump turn over presidential records that he had kept after his presidency. On multiple occasions beginning in June, Nara warned Trump through his representatives that if he did not comply, it would refer the matter of the missing records to the Department of Justice. Thirty eight. Between November twenty twenty one and January twenty twenty two, NADA and Trump employee two at Trump’s direction. Brought boxes from the storage room to Trump’s residence for Trump to review.

Thirty nine. On November twelfth twenty twenty one, Trump employee two provided Trump a photograph of his boxes in the storage room by taping it to one of the boxes that Trump employee two had placed in Trump’s residence. Trump employee too provided Trump the photograph so that Trump forty. On November seventeenth twenty twenty one, Not a texted Trump employee too about the photograph Trump employee too had provided to Trump stating, he mentioned about a picture of the box says he wants me to see it. Trump employee too replied, calling you shortly.

Forty one. On November twenty fifth twenty twenty one, Trump employee two texted NADA about Trump’s review of the contents of his boxes asking, Has he mentioned boxes to you? I delivered some but I think he may need more. Could you ask if he’d like more in Pine Hall? Pine Hall was an entry room in Trump’s residence.

Naughta replied in three successive text messages. Nothing about boxes yet. He has one he’s working on in Pine Hall, knocked out two boxes yesterday, forty two. On November twenty ninth twenty twenty one, Trump employee too texted Nauta asking, next you are on property.

No rush. Could you help me bring four more boxes up? Nada replied, yes, of course. Forty three. On December twenty ninth twenty twenty one, Trump employee too texted a Trump representative who was in contact with Nora.

Trump representative won. Box answer will be wrenched out

of him today. Promise. The next day, Trump representative one replied in two successive text messages. Could see how many of his boxes were stored in the storage room. Hey, just checking on boxes.

Would love to have a number to them today. Trump employee too spoke to Trump, and then responded a few hours later in two successive text messages. Twelve is his number, forty four. On January thirteenth, twenty twenty two, Nada texted Trump employee too about Trump’s tracking of boxes stating, he’s tracking the boxes. More to follow today on whether he wants to go through more today or tomorrow.

Trump employee too replied, thank you. Forty five. On January fifteenth twenty twenty two, Nada sent Trump employee two four successive text messages. One thing he asked was for new covers for the boxes. For Monday, m a morning asterisk, can we get new box covers before giving these to them on Monday?

They have too much writing on them. I marked too much. Trump employee too replied, yes, I will get that. Forty six. On January seventeenth twenty twenty two, Trump employee too and NADA gathered fifteen boxes from Trump’s residence, loaded the boxes in NADA’s car, and took them to a commercial truck for delivery to Nara.

Forty seven. When interviewed by the FBI in May twenty twenty two, regarding the location and movement of boxes before the production to Nara. NADA made false and misleading statements as set forth in count thirty eight of this indictment. Including a. Falsely stating that he was not aware of Trump’s boxes being brought to Trump’s residence for his review.

Before Trump provided fifteen boxes to Nara in January twenty twenty two. B falsely stating that he did not know how the box is that he and Trump employee too brought from Trump’s residence to the commercial truck for delivery to Nara on January seventeenth twenty twenty two had gotten to the residence. And c, when asked whether he knew where Trump’s boxes had been stored before they were in Trump’s residence, and whether they had been in a secure or locked location. Not a falsely responded.

I wish I wish I

could tell you. I don’t know. I don’t. I honestly just don’t know. Forty eight.

When the fifteen boxes that Trump had provided reached Nara in January twenty twenty two, Nara reviewed the contents and determined that fourteen of the boxes contained documents with classification markings. Specifically, as the FBI later determined, the boxes contained one hundred ninety seven documents with classification markings. Of which ninety eight were marked secret. Thirty were marked top Secret Podcast remainder were marked confidential. Some of those documents also contained SCI and SAP markings.

Forty nine. On February ninth twenty twenty two, Nara referred the discovery of classified documents in Trump’s boxes to the Department of Justice for Investigation. The FBI and grand jury investigations,

Fifty. On March thirtieth twenty twenty two, the FBI opened a criminal investigation. Fifty one. On April twenty sixth twenty twenty two, a

federal grand jury opened an investigation. The defendant’s concealment of boxes. Fifty two. On May eleventh twenty twenty two, the grand jury issued a subpoena. The May eleventh subpoena to the office of Donald j Trump requiring the production of all documents with classification markings in the possession, custody, or control of Trump or the office of Donald j Trump.

Two attorneys representing Trump, Trump attorney one and Trump attorney two, informed Trump of the May eleventh subpoena. And he authorized Trump attorney one to accept service. Fifty three. On May twenty second twenty twenty two, NADA entered the storage room at three forty seven PM and left approximately thirty four minutes later, carrying one of Trump’s boxes. Fifty four.

On May twenty third twenty twenty two, Trump met with Trump attorney one and Trump attorney two at the Mar a Lago club to discuss the response to the May eleventh subpoena. Trump attorney one and Trump attorney two told Trump that they needed to for documents that would be responsive to the subpoena and provide a certification that there had been compliance with the subpoena. Trump, in some Ron DeSantis, made the following statements among others, as memorialized by Trump attorney one, a, I don’t want anybody looking. I don’t want anybody looking through my boxes. I really don’t.

I don’t want you looking through my boxes. B. Well, what if we

what happens? If we just don’t respond at all or don’t play ball with them? C. Wouldn’t it be better if we just told them we don’t have anything here? D.

Well, look, isn’t it better if there are no documents? Fifty five. While meeting with Trump attorney one and Trump attorney two on May twenty third, Trump, in some and substance, told the following story as memorialized by Trump attorney won. Attorney, he was great. He did a great job.

You know what? He said he said that it that it was him, that he was the one who deleted all

of her emails. The thirty thousand emails because they basically dealt with her scheduling and her going to the gym and her having beauty appointments. And he was great. And he so she didn’t get in any trouble because he said that he was the one who deleted them. Trump related the story more than once that day, fifty six.

On May twenty third, Trump also confirmed his understanding with Trump attorney one that Trump attorney one would return to the Mar a Lago club on June second to search for any documents with classification markings to produce in response to the May eleventh subpoena. Trump attorney one made it clear to Trump that Trump attorney one would conduct the search for responsive documents by looking through Trump’s boxes that had been transported from the White House and remained in storage at the Mar

a Lago club. Trump indicated that he wanted to be at the Mar a

Lago club when Trump attorney won returned to review his boxes on June second and that Trump would change his summer travel plans to do so. Trump told Trump attorney two that Trump attorney two did not need to be present for the review of boxes. Fifty seven. After meeting with Trump attorney one and Trump attorney two on May twenty third, Trump delayed his departure from the Mar

a Lago club to the Bedminster club for the summer so that he

would be present at the Mar a Lago club on June second when Trump attorney won returned to review the boxes. Fifty eight. Between Trump’s May twenty third meeting with Trump attorney one and Trump attorney two to discuss the May eleventh subpoena, And June second, when Trump attorney won returned to the Mar a Lago club to review the boxes in the storage room, Nada removed at Trump’s direction. A total of approximately sixty four boxes from the storage room and brought them to Trump’s residence as set forth below a. On May twenty fourth, twenty twenty two, between five thirty PM and five thirty eight PM.

NADA removed three boxes from the storage room. B. On May thirtieth twenty twenty two at nine zero eight AM, Trump and Nada spoke by phone for approximately thirty seconds, Between ten o two AM and eleven fifty one AM, Nada removed a total of approximately fifty boxes from the storage room. C, on May thirtieth twenty twenty two at twelve thirty three PM, a Trump family member texted NADA. Good afternoon, Walt.

Happy Memorial Day. I saw you put boxes to Potus Room. Just FYI and I will tell him as well. Not sure how many he wants to take on Friday on the plane. We will not have a room for them.

Plain will be full with luggage. Thank you. Nada replied. Good afternoon, ma’am, smiley face emoji. Thank you so much.

I think he wanted to pick from them. I don’t imagine him wanting to take the boxes. He told me to put them

in the room and that he was going to talk to you about them. D.

On June first twenty twenty two, beginning at twelve fifty two PM, not a removed approximately eleven boxes from the storage room. Fifty nine. On June first, twenty twenty two, Trump spoke with Trump attorney one by phone and asked whether Trump attorney one was coming to the Mar a Lago club the next day and for exactly what purpose. Trump attorney one reminded Trump that Trump attorney one was going to review the boxes that had been transported from the White House and remained in storage at the Mar a Lago club. So that Trump attorney one could have a custodian of records, certify that the May eleventh subpoena had been complied with fully.

Sixty. On June second twenty twenty two, the day that Trump attorney won was scheduled to review Trump’s boxes in the storage room, Trump spoke with NADA on the phone at nine twenty nine AM for approximately twenty four seconds. Sixty one. Later that day, between twelve thirty three PM and twelve fifty two PM, NADA and an employee of the Mar a Lago Club, moved approximately thirty boxes from Trump’s residence to the storage room. Sixty two.

In some, between May twenty third, twenty twenty two, And June second twenty twenty two, before Trump attorney won’s review of Trump’s boxes in the storage room, NADA at Trump’s direction. Moved approximately sixty four boxes from the storage room to Trump’s residence and brought to the storage room only approximately thirty boxes. Neither Trump nor NADA informed Trump attorney one of this information. The false certification to the FBI and the grand jury. Sixty three, On the afternoon of June second twenty twenty two, as Trump had been informed, Trump attorney one arrived at the Mar a Lago club to review Trump’s boxes to look for documents with classification markings in response to the May eleventh subpoena.

Trump met with Trump attorney one before Trump attorney one conducted the review. NADA escorted Trump attorney one to the storage room. Sixty four. Between three fifty three PM and six twenty three PM, Trump attorney one reviewed the contents of Trump’s boxes in the storage room. Trump attorney one located thirty eight documents with classification markings inside the boxes.

Which Trump attorney one removed and placed in a Redweld folder. Trump attorney one contacted NADA and asked him to bring clear duct tape to the storage room. Which not a did. Trump attorney one used the clear duct tape to seal the Redweld folder with the documents with classification markings inside. Sixty five.

After Trump attorney one finished sealing the Redweld folder containing the documents with classification markings that he had found inside Trump’s Noda took Trump attorney one to a dining room in the Mar a Lago club to meet with Trump. After Trump attorney one confirmed that he was finished with search of the storage room, Trump asked, did you find anything? Is it bad? Good? Sixty six.

Trump and Trump attorney won, then discussed what to do with the Redweld folder containing documents with classification markings And whether Trump attorney one should bring them to his hotel room and put them in

a safe there. During that conversation, Trump

made a plucking motion. As memorialized by Trump attorney won. He made a funny motion as though, well okay, why don’t you take them with you to your hotel room and if there’s anything really bad in there, like, you know, pluck it out. And that was the motion that he made. He didn’t say that.

Sixty seven. That evening, Trump attorney one contacted the Department of Justice and requested that an FBI agent meet him at the Mar a Lago club the next day. June third, so that he could turn over the documents responsive to the May eleventh subpoena. Sixty eight. Also that evening, Trump attorney one contacted another Trump attorney.

Trump attorney three and asked her if she would come to the Mar a Lago club the next morning to act as a custodian of records and sign a certification regarding the search for documents with classification markings in response to the May eleventh subpoena. Trump attorney three who had no role in the review of Trump’s boxes

in the storage room agreed. Sixty nine. The next day, on June third twenty twenty two, at Trump attorney one’s request, Trump attorney three signed certification

as the custodian of records for the office of Donald j Trump and took it to the Mar a lago club to provide it to the Department of Justice and FBI. In the certification, Trump attorney three, who performed no search of Trump’s boxes, had not reviewed the May eleventh subpoena and had not reviewed the contents of the Redweld folder, stated among other things that based upon the information that had been provided to her. 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. Seventy. These statements were false because among other reasons, Trump had directed NADA to move boxes before Trump attorney won’s June second review so that many boxes were not searched. And many documents responsive to the May eleventh subpoena could not be found.

And in fact, were not found by Trump attorney one. Seventy one. Shortly after Trump Attorney three executed the false certification on June third twenty twenty two, Trump attorney won and Trump attorney three met at the Mar a Lago club with personnel from the Department of Justice and FBI. Trump attorney one and Trump attorney three turned over the Redweld folder containing documents with classification markings, as well as false certification signed by Trump Attorney three as custodian of records. Trump, who had delayed his departure from the Mar a Lago club, joined Trump attorney one and Trump attorney three for some of the meeting.

Trump claimed to the Department of Justice and FBI that he was an open book Seventy two. Earlier that same day, NADA and others loaded several of Trump’s boxes along with other items on aircraft that flew Trump and his family north for the summer. The court authorized search of the Mar a Lago club seventy three. In July twenty twenty two, the FBI and grand jury obtained and reviewed surveillance video from the Mar a Lago Club showing the movement of boxes set forth above. Seventy four.

On August eighth twenty twenty two, the FBI executed a court authorized search warrant at the Mar a Lago Club. The search warrant authorized the FBI to search for and seize among other things, all documents with classification markings. Seventy five. During the execution of the warrant at the Mar a Lago club, the FBI seized one hundred two documents classification markings in Trump’s office and the storage room. The conspiracy and its objects, seventy nine From on or about May eleventh twenty twenty two, through in or around August twenty twenty two.

In Palm Beach County, in the southern district of Florida and elsewhere. The defendants, Donald j Trump and Walton NADA 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 eighteen USC, and to corruptly conceal a record, document, and other object from an official proceeding in violation of eighteen USC, the purpose of the conspiracy. Eighty.

The purpose of the conspiracy was for Trump to keep classified documents he had taken with him from the White House and to hide and conceal them from a federal grand jury. The manner and means of the conspiracy. Eighty one. The manner and means by which the defendants sought to accomplish the objects and purpose of the conspiracy included, among other things, the following. A, suggesting that Trump attorney one fall represent to the FBI and grand jury that Trump did not have documents called for by the May eleventh subpoena.

B, moving boxes of documents to conceal them from Trump attorney one, the FBI, and the grand jury. C, suggesting that Trump attorney won, hide or destroy documents called for by the May eleventh subpoena. D, providing to the FBI and grand jury, just some of the documents called for by the May eleventh subpoena, while Trump claimed he was cooperating fully. E, causing a false certification to be submitted to the FBI and grand jury, representing that all documents with classification markings had been produced when in fact they had not. And f making false and misleading statements to the FBI.

All in violation of title eighteen, United States code, section fifteen twelve, eighty three. From Honor about May eleventh twenty twenty two, through in or around August twenty twenty two in Palm Beach County in the southern district of Florida and elsewhere. The defendants Donald j Trump and Walton Naughta did knowingly engage in misleading conduct toward another person and knowingly corruptly persuade an 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, one, Trump attempted to persuade Trump attorney one to hide and conceal documents from a federal grand jury. And two, Trump and Nada misled Trump attorney one by moving boxes that contain documents with classification markings, so that Trump attorney won would not find the documents and produce them to a federal grand jury.

All in violation of title eighteen, United States code sections fifteen twelve. Eighty five. From on or about May eleventh twenty twenty two, threw in or around August twenty twenty two in Palm Beach County in the southern district of Florida and elsewhere. The defendants Donald j Trump and Walton Naughta 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 Nada hid and concealed boxes that contained documents with classification markings from Trump attorney one so that Trump attorney one would not find the documents and produce them to a federal grand jury. All in violation of title eighteen, United States code sections fifteen twelve eighty seven. From on or about May eleventh twenty twenty two, through in or around August twenty twenty two, in Palm Beach County, in the Southern District of Florida and elsewhere. The defendants, Donald j Trump and Waltin NADA, 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, during a federal criminal investigation being conducted by the FBI, won.

Trump and not 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 two, Trump caused a false certification to be submitted to

the FBI All in violation of title eighteen, United States code sections fifteen nineteen and two eighty nine. From on

or about May eleventh twenty twenty two, through in or around August twenty twenty two in Palm Beach County, in the Southern District of Florida and elsewhere. The defendants, Donald j Trump and Walton NADA. 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 not a hid and concealed from the grand jury and the FBI. Trump’s continued possession of documents with classification markings.

All in violation of title eighteen, United States code sections one hundred and two, count thirty seven. Follow statements and representations eighteen USC ninety. The general allegations of this indictment are re alleged and fully incorporated here by reference. Ninety one. On or about June third twenty twenty two 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 following false statements and representations to be made to the grand jury and the FBI in a sworn certification executed by Trump attorney three. 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. Ninety two. 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 one conducted the June second twenty twenty two search for documents with classification markings.

So that Trump attorney won search would not and did not include all of Trump’s boxes that were removed from the White House. Trump attorney won search would not and did not locate all documents responsive to the May eleventh subpoena. And all responsive documents were provided to the FBI and the grand jury with the certification. In fact, after June third, twenty twenty two, More than one hundred documents with classification markings remained at the Mar a Lago Club until the FBI search on August eighth twenty twenty two. All in violation of title eighteen, United States code, sections one thousand one, count thirty eight false statements and representations.

Eighteen USC. Ninety four. On May twenty sixth twenty twenty two, NADA participated in a voluntary interview with the FBI. During the interview, the FBI explained to Nada that the FBI was investigating how classified documents had been kept at the Mar a Lago club. And the FBI asked Nada questions about the location and movement of Trump’s boxes before Trump provided fifteen boxes to Nara on January seventeenth.

Twenty twenty two. NADA was represented by counsel, and the FBI advised NADA that the interview was voluntary and that he could leave at any time. The FBI also advised NADA that it was a criminal offense to lie to the FBI. The interview was recorded, ninety five. Honor about May twenty sixth, twenty twenty two, in Palm Beach County, in the Southern District of Florida and elsewhere.

The defendant, Walton Naughtah, in a matter within the jurisdiction of the executive branch of the United States government. Did knowingly and willfully make a materially false, fictitious, and fraudulent statement and representation? That is, in a voluntary interview during a federal criminal investigation being conducted by the FBI, NADA was asked the following questions. And gave the following false answers.

Question. Does any are you aware of any boxes being brought to his home? His sweet? Answer? No.

Asterisk asterisk asterisk.

Question. Alright. So so to the best of your knowledge, you’re saying that those boxes that you brought onto the truck, first time you ever laid eyes on them was just the day of when Trump employee too needed you to answer. Correct.

Question. To take them. Okay.

Question. In knowing that we’re trying to track the life of these boxes and where they could have been kept and stored and all that kind of stuff?

Answer. Mhmm. Question, Do you have any information that could, that would, that could help us understand like where they were kept, how they were kept, where they secured, Were they locked? Something that makes the intelligence community feel better about these things, you know? I wish I wish I could tell you.

I don’t know. I don’t I honestly just don’t know. Question. And what? So so you only saw

the fifteen boxes, fifteen seventeen boxes. Answer. Mhmm.

Question. The day of the move, even they just showed up that day. Answer they were in Pine Hall. Trump employee too. Just asked me, hey, can we move some boxes?

Question. Okay. Answer. And I was like, Okay.