Bonus Episode: Listen to the Superseding Indictment

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Speaker 6 The following is a reading of the Trump Classified Documents superseding indictment.

Speaker 10 Parts of the text have been edited for clarity and ease of listening.

Speaker 14 The recording was produced using an artificial voice generator.

Speaker 15 United States of America v.

Speaker 12 Donald J.

Speaker 9 Trump, Waltine Nada, and Carlos de Oliveira, superseding indictment.

Speaker 19 The grand jury charges that, one,

Speaker 21 defendant Donald J.

Speaker 15 Trump was the 45th President of the United States of America.

Speaker 26 He held held office from January 20th, 2017 until January 20th, 2021.

Speaker 15 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.

Speaker 38 2.

Speaker 42 Over the course of his presidency, Trump gathered gathered newspapers, press clippings, letters, notes, cards, photographs, official documents, and other materials in cardboard boxes that he kept in the White House.

Speaker 47 Among the materials Trump stored in his boxes were hundreds of classified documents.

Speaker 49 3.

Speaker 15 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 of the United States and its allies to military attacks, and plans for possible retaliation in response to a foreign attack.

Speaker 58 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.

Speaker 61 4.

Speaker 62 At 12 p.m.

Speaker 26 on January 20th, 2021, Trump ceased to be president.

Speaker 7 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.

Speaker 25 Trump was not authorized to possess or retain those classified documents.

Speaker 71 5.

Speaker 25 The Mara Lago Club was an active social club, which, between January 2021 and August 2022, hosted events for tens of thousands of members and guests.

Speaker 76 After Trump's presidency, the Mara Lago Club was not an authorized location for the storage, possession, review, display, or discussion of classified documents.

Speaker 81 Nevertheless, Trump stored his boxes containing classified documents in various locations at the Mara Lago Club, including in a ballroom, a bathroom and shower, an office space, his bedroom, and a storage room.

Speaker 12 On two occasions in 2021, Trump showed classified documents to others as follows.

Speaker 38 A.

Speaker 39 In July 2021, 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.

Speaker 53 Trump told the individuals that the plan was highly confidential and secret.

Speaker 93 Trump also said, as president, I could have declassified it, and now I can't, you know, but this is still a secret.

Speaker 38 B.

Speaker 36 In August or September 2021, 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.

Speaker 27 7.

Speaker 12 On March 30th, 2022, the Federal Bureau of Investigation, FBI, opened a criminal investigation into the unlawful retention of classified documents at the Mara Lago Club.

Speaker 66 A federal grand jury investigation began the next month.

Speaker 33 The grand jury issued a subpoena requiring Trump to turn over all documents with classification markings.

Speaker 9 Trump endeavored to obstruct the FBI FBI and grand jury investigations and conceal his continued retention of classified documents by,

Speaker 107 among other things, A, suggesting that his attorney falsely represented to the FBI and grand jury that Trump did not have documents called for by the grand jury subpoena.

Speaker 7 B, directing defendant Walteen Nada to move boxes of documents to conceal them from Trump's attorney, the FBI, and the grand jury.

Speaker 67 C, suggesting that his attorney hide or destroy documents called for by the grand jury subpoena, D.

Speaker 47 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.

Speaker 55 E.

Speaker 110 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, and F attempting to delete security camera footage at the Mar-a-Lago Club to conceal information from the FBI and grand jury.

Speaker 112 8.

Speaker 7 As a result of Trump's retention of classified documents after his presidency and refusal to return them, hundreds of classified documents were not recovered by the United States government until 2022, as follows.

Speaker 10 Aya, on January 17th, 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 15 boxes, which contained 197 documents with classification markings.

Speaker 38 B.

Speaker 105 On June 3rd, in response to a grand jury subpoena demanding the production of all documents with classification markings, Trump's attorney provided to the FBI 38 more documents with classification markings.

Speaker 38 C.

Speaker 65 On August 8th, pursuant to a court-authorized search warrant, the FBI recovered from Trump's office and a storage room at the Mar-a-Lago Club 102 more documents with classification markings.

Speaker 51 Trump's co-conspirators.

Speaker 117 9.

Speaker 11 Defendant Nada was a member of the United States Navy stationed as a valet in the White House during Trump's presidency.

Speaker 51 Beginning in August 2021, Nada became an executive assistant in the office of Donald J.

Speaker 74 Trump and served as Trump's personal aide or bodyman.

Speaker 97 Nada reported to Trump, worked closely with Trump, and traveled with Trump.

Speaker 18 Beginning in January 2022, defendant Carlos De Oliveira was employed as the property manager at the Mara Lago Club.

Speaker 18 Prior to holding the position of property manager, De Oliveira was employed as a valet at the Mara Lago Club.

Speaker 81 The Mara Lago Club.

Speaker 119 11.

Speaker 84 The Mara Lago Club was located on South Ocean Boulevard in Palm Beach, Florida, and included Trump's residence, more than 25 guest rooms, two ballrooms, a spa, a gift store, exercise facilities, office space, and an outdoor pool and patio.

Speaker 25 As of January 2021, the Mar-a-Lago Club had hundreds of members and was staffed by more than 150 full-time, part-time, and temporary employees, 12.

Speaker 12 Between January 2021 and August 2022, the Mar-a-Lago Club hosted more than 150 social events, including weddings, movie premieres, and fundraisers that together drew tens of thousands of guests.

Speaker 10 13.

Speaker 45 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.

Speaker 12 Trump did not inform the Secret Service that he was storing boxes containing classified documents at the Mar-a-Lago Club.

Speaker 89 Classified Information.

Speaker 10 14.

Speaker 9 National Security Information was information owned by, produced by, produced for and under the control of the United States government.

Speaker 40 Pursuant to Executive Order 12958 signed on april 17, 1995, as amended by Executive Order 13292 on march 25th, 2003 and Executive Order 13526 on December 29, 2009, national security information was classified as top secret, secret, or confidential as follows.

Speaker 38 A.

Speaker 127 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.

Speaker 38 B.

Speaker 9 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.

Speaker 38 C.

Speaker 48 Information was classified as confidential.

Speaker 25 If the unauthorized disclosure of that information reasonably could be expected to cause damage to the national security that the original classification authority was able to identify or describe.

Speaker 131 15.

Speaker 118 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.

Speaker 11 16.

Speaker 103 Classified information related to intelligence sources, methods, and analytical processes was designated as sensitive compartmented information.

Speaker 34 SCI was to be processed, stored, used, or discussed in an accredited sensitive compartmented information facility, SCIF, and only individuals with the appropriate security clearance and additional SCI permissions were authorized to have access to such national security information.

Speaker 37 17.

Speaker 48 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

Speaker 48 to further protect the classified information.

Speaker 55 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.

Speaker 86 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.

Speaker 16 18.

Speaker 36 Pursuant to Executive Order 13526, information classified at any level could be lawfully accessed 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.

Speaker 127 After his presidency, presidency, Trump was not authorized to possess or retain classified documents.

Speaker 59 19.

Speaker 83 Executive Order 13526 provided that a former president could obtain a waiver of the need to know requirement if the agency head or senior agency 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.

Speaker 55 Trump did not obtain any such waiver after his presidency.

Speaker 7 The executive branch departments and agencies, whose classified documents Trump retained after his presidency.

Speaker 107 20.

Speaker 12 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.

Speaker 51 He regularly received a collection of classified intelligence from the United States Intelligence Community, USIC, known as the President's Daily Brief.

Speaker 26 21.

Speaker 39 The USIC's mission was to collect, analyze, and deliver foreign intelligence and counterintelligence 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.

Speaker 13 The USIC consisted of United States executive branch departments and agencies responsible for the conduct of foreign relations and the protection of national security.

Speaker 26 22.

Speaker 127 After his presidency, Trump retained classified documents originated by or implicating the equities of multiple USIC members and other executive branch departments and agencies, including the following.

Speaker 35 A, the Central Intelligence Agency, CIA.

Speaker 55 CIA was responsible for providing intelligence on foreign countries and global issues to the president and other policymakers to help them make national security decisions.

Speaker 36 B, the Department of Defense, DOD.

Speaker 9 DOD was responsible for providing the military forces needed to deter war and ensure national security. Some of the executive branch agencies comprising the USIC were within DOD, C.

Speaker 70 The National Security Agency.

Speaker 79 The National Security Agency was a combat support agency within DOD and a member of the USIC responsible for foreign signals intelligence and cybersecurity.

Speaker 9 This included collecting, processing, and disseminating to United States policymakers and military leaders foreign intelligence derived from communications and information systems, protecting national security systems, and enabling computer network operations.

Speaker 141 D.

Speaker 35 The National Geospatial Intelligence Agency.

Speaker 9 The National Geospatial Intelligence Agency was a combat support agency within DOD responsible for the exploitation and analysis of imagery, imagery intelligence, and geospatial information in support of the national security objectives of the United States and the geospatial intelligence requirements of DOD, the Department of State, and other federal agencies.

Speaker 99 E.

Speaker 42 The National Reconnaissance Office.

Speaker 11 The National Reconnaissance Office was an agency within DOD responsible for developing, acquiring, launching, and operating space-based surveillance and reconnaissance systems that collected and delivered intelligence to enhance national security.

Speaker 23 F, the Department of Energy.

Speaker 12 The Department of Energy was responsible for maintaining a safe, secure, and effective nuclear deterrent to protect national security, including ensuring the effectiveness of the United States nuclear weapons stockpile without nuclear explosive testing.

Speaker 38 G.

Speaker 122 The Department of State and Bureau of Intelligence and Research.

Speaker 15 The Department of State was responsible for protecting and promoting United States security, prosperity, and democratic values.

Speaker 78 Within the Department of State, the Bureau of Intelligence and Research was a member of the USIC and responsible for providing intelligence to inform diplomacy and support United States diplomats.

Speaker 50 diplomats. Trump's public statements on classified information, 23.

Speaker 56 As a candidate for President of the United States, Trump made the following public statements, among others, about classified information.

Speaker 38 A.

Speaker 34 On August 18, 2016, Trump stated, In my administration, I'm going to enforce all laws concerning the protection of classified information.

Speaker 20 No one will be above the law.

Speaker 38 B.

Speaker 78 On September 6, 2016, Trump stated, we also need to fight this battle by collecting intelligence and then protecting, protecting our classified secrets.

Speaker 13 We can't have someone in the Oval Office who doesn't understand the meaning of the word confidential or classified.

Speaker 38 C.

Speaker 65 On September 7th, 2016, 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.

Speaker 26 24.

Speaker 145 As President of the United States, on July 26, 2018, Trump issued the following statement about classified information.

Speaker 51 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.

Speaker 10 More broadly, the issue of a former executive branch official's security clearance raises larger questions about the practice of of former officials maintaining access to our nation's most sensitive secrets long after their time in government has ended.

Speaker 40 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.

Speaker 21 Any access granted to our nation's secrets should be in furtherance of national, not personal interests.

Speaker 7 Trump's retention of classified documents after his presidency.

Speaker 80 25.

Speaker 69 In January 2021, 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.

Speaker 104 Trump was personally involved in this process.

Speaker 7 Trump caused his boxes, containing hundreds of classified documents, to be transported from the White House to the Mar-a-Lago Club.

Speaker 73 26.

Speaker 115 From January through March 15th, 2021, some of Trump's boxes were stored in the Mara Lago Club's white and gold ballroom, in which events and gatherings took place.

Speaker 84 Trump's boxes were for a time stacked on the ballroom's stage.

Speaker 45 27.

Speaker 12 In March 2021, Nada and others moved some of Trump's boxes from the White and Gold Ballroom to the business center at the Mara Lago Club.

Speaker 26 28.

Speaker 70 On April 5th, 2021, an employee of the office of Donald J.

Speaker 47 Trump, Trump Employee 1, texted another employee of that office, Trump Employee 2, 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.

Speaker 78 Trump Employee 2 replied, Whoa, okay, so POTUS specifically asked Walt for those boxes to be in the business center because they are his papers.

Speaker 94 Later that day, Trump Employee 1 and Trump Employee 2 exchanged the following text messages.

Speaker 80 Trump employee.

Speaker 32 2.

Speaker 9 We can definitely make it work if we move his papers into the lake room.

Speaker 80 Trump employee.

Speaker 103 1.

Speaker 133 There is still a little room in the shower where his other stuff is.

Speaker 150 Is it only his papers he cares about?

Speaker 12 There's some other stuff in there that are not papers.

Speaker 129 Could that go to storage?

Speaker 90 Or does he want everything in there on the property?

Speaker 80 Trump employee.

Speaker 58 2.

Speaker 12 Yes, anything that's not the beautiful mind paper boxes can definitely go to storage.

Speaker 150 Want to take a look at the space and start moving tomorrow AM?

Speaker 26 29.

Speaker 26 After the text exchange between Trump Employee 1 and Trump Employee 2 in April 2021, 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.

Speaker 86 30.

Speaker 115 In May 2021, 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.

Speaker 122 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.

Speaker 126 The storage room was near the liquor supply closet, linen room, lock shop, and various other rooms.

Speaker 112 31.

Speaker 149 On June 24th, 2021, Trump's boxes that were in the lake room were moved to the storage room.

Speaker 12 After the move, there were more than 80 boxes in the storage room, 32.

Speaker 66 On December 7, 2021, Nada found several of Trump's boxes fallen and their contents spilled onto the floor of the storage room, including a document marked Secret, which denoted that the information in the document was releasable only to the Five Eyes Intelligence Alliance consisting of Australia, Canada, New Zealand, the United Kingdom, and the United States.

Speaker 12 Nada texted Trump employee to,

Speaker 133 I opened the door and found this.

Speaker 22 Nada also attached two photographs he took of the spill.

Speaker 137 Trump employee two replied, oh no, oh no, and I'm sorry POTUS had my phone.

Speaker 36 One of the photographs Nada texted to Trump Employee 2 is depicted below with the visible classified information redacted.

Speaker 13 Trump's unlawful retention of this document is charged in Count 8 of this superseding indictment.

Speaker 55 Trump's Disclosures Disclosures of Classified Information in Private Meetings, 33.

Speaker 12 In May 2021, Trump caused some of his boxes to be brought to his summer residence at the Bedminster Club.

Speaker 75 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.

Speaker 152 34.

Speaker 40 On July 21st, 2021, 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.

Speaker 145 Two members of Trump's staff also attended the interview, which was recorded with Trump's knowledge and consent.

Speaker 75 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.

Speaker 152 35.

Speaker 39 Upon greeting the writer, publisher, and his two staff members, Trump stated, Look what I found.

Speaker 36 This was the senior military official's plan of attack.

Speaker 79 Read it, and it shows.

Speaker 30 It's interesting.

Speaker 91 Later in the interview, Trump engaged in the following exchange.

Speaker 75 Trump, well, with the senior military official, uh, let me see that.

Speaker 17 I'll show you an example.

Speaker 9 He said that I wanted to attack country A.

Speaker 13 Isn't it amazing?

Speaker 60 I have a big pile of papers.

Speaker 13 This thing just came up.

Speaker 63 Look, this was him.

Speaker 40 They presented me this.

Speaker 56 This is off the record, but they presented me this.

Speaker 63 This was him.

Speaker 36 This was the Defense Department and him.

Speaker 32 Writer.

Speaker 115 Wow?

Speaker 71 Trump.

Speaker 84 We looked at some. This was him.
This wasn't done by me.

Speaker 8 This was him.

Speaker 28 All sorts of stuff.

Speaker 8 Pages long. Look.

Speaker 140 Wait a minute. Let's see here.

Speaker 85 Staffer. Laughter.

Speaker 155 Yeah?

Speaker 71 Trump.

Speaker 51 Except it is like highly confidential.

Speaker 85 Staffer.

Speaker 121 Yeah.

Speaker 85 Laughter.

Speaker 71 Trump.

Speaker 63 Secret.

Speaker 9 This is secret information.

Speaker 56 Look, look at this.

Speaker 7 You attack.

Speaker 109 And by the way, isn't that incredible?

Speaker 85 Staffer.

Speaker 156 Yeah?

Speaker 71 Trump.

Speaker 13 I was just thinking because we were talking about it.

Speaker 9 And you know, he said he wanted to attack country A.

Speaker 100 And what?

Speaker 8 This was done by the military and given to me.

Speaker 154 Uh, I think we can probably, right?

Speaker 93 See, as president, I could have declassified it.

Speaker 85 Staffer.

Speaker 101 Yeah.

Speaker 39 Laughter.

Speaker 109 Now we have a problem.

Speaker 71 Trump.

Speaker 111 Isn't that interesting?

Speaker 25 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.

Speaker 26 The document that Trump possessed and showed on July 21st, 2021 is charged as Count 32 in this superseding indictment.

Speaker 113 36.

Speaker 158 In August or September, 2021, 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.

Speaker 6 During the meeting, Trump commented that an ongoing military operation in Country B was not going well.

Speaker 51 Trump showed the PAC 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.

Speaker 26 The PC representative did not have a security clearance or any need to know classified information about the military operation.

Speaker 64 37.

Speaker 65 On February 16th, 2017, 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?

Speaker 24 How do they do it?

Speaker 132 You know why?

Speaker 129 Because it's an illegal process, and the press should be ashamed of themselves.

Speaker 30 But more importantly, the people that gave out the information to the press should be ashamed of themselves.

Speaker 75 Really ashamed.

Speaker 123 Trump's production of 15 cardboard boxes to the National Archives and Records Administration.

Speaker 112 38.

Speaker 102 Beginning in May 2021, the National Archives and Records Administration, NARA, which was responsible for archiving presidential records, repeatedly demanded that Trump tum over presidential records that he had kept after his presidency.

Speaker 70 On multiple occasions.

Speaker 21 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.

Speaker 103 39.

Speaker 26 Between November 2021 and January 2022, Nada and Trump Employee 2, at Trump's direction, brought boxes from the storage room to Trump's residence for Trump to review.

Speaker 152 40.

Speaker 12 On November 12, 2021, Trump Employee 2 provided Trump a photograph of his boxes in the storage room by taping it to one of the boxes that Trump employee 2 had placed in Trump's residence.

Speaker 56 Trump Employee 2 provided Trump the photograph so that Trump could see how many of his boxes were stored in the storage room.

Speaker 124 The photograph shown below depicted a wall of the storage room against which dozens of Trump's boxes were stacked.

Speaker 112 41.

Speaker 59 On November 17th, 2021, Nada texted Trump Employee 2 about the photograph Trump Employee 2 had provided to Trump, stating, he mentioned about a picture of the boxes he wants me to see it.

Speaker 137 Trump employee 2 replied, calling you shortly, 42.

Speaker 55 On November 25th, 2021, Trump Employee 2 texted Nada about Trump's review of the contents of his boxes, asking, Has he mentioned boxes to you?

Speaker 154 I delivered delivered some, but I think he may need more.

Speaker 150 Could you ask if he'd like more in Pine Hall?

Speaker 49 Pine Hall was an entry room in Trump's residence.

Speaker 53 Nada replied in three successive text messages.

Speaker 39 Nothing about boxes yet.

Speaker 33 He has one he's working on in Pine Hall, knocked out two boxes yesterday.

Speaker 43 43.

Speaker 93 On November 29th, 2021, Trump employee two texted Nada asking, Next you are on property, no rush, could you help me bring four more boxes up?

Speaker 69 Nada replied, Yes, of course, 44.

Speaker 76 On December 29th, 2021, Trump employee two texted a Trump representative who was in contact with NARA.

Speaker 83 Box answer will be wrenched out of him today.

Speaker 98 Promise.

Speaker 20 The next day, Trump Representative 1 replied in two successive text messages.

Speaker 23 Hey, just checking on boxes.

Speaker 158 Would love to have a number to them today.

Speaker 76 Trump employee 2 spoke to Trump and then responded a few hours later in two successive text messages.

Speaker 10 12 is his number, 45.

Speaker 7 On January 13th, 2022, Nada texted Trump Employee 2 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.

Speaker 137 Trump Employee 2 replied, thank you.

Speaker 64 46.

Speaker 88 On January 1s, 2022, Nada sent Trump Employee 2 four successive text messages.

Speaker 123 One thing he asked asked was for new covers for the boxes for Monday morning.

Speaker 40 Can we get new box covers before giving these to them on Monday?

Speaker 55 They have too much writing on them.

Speaker 23 I marked too much.

Speaker 137 Trump employee two replied, Yes, I will get that.

Speaker 64 47.

Speaker 47 On January 17th, 2022, Trump employee two and Nada gathered 15 boxes from Trump's residence, loaded the boxes in Nada's car, and took them to a commercial truck for delivery to NARA.

Speaker 152 48.

Speaker 9 When interviewed by the FBI in May 2022 regarding the location and movement of boxes before the production to NARA, NARDA made false and misleading statements as set forth in Count 38 of this superseding 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 15 boxes to NARA in January 2022, B falsely stating that he did not know how the boxes that he and Trump employee Two brought from Trump's residence to the commercial truck for delivery to NARA on January 17, 2022, had gotten to the residence.

Speaker 38 And C.

Speaker 11 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, Nada falsely responded, I wish, I wish I could tell you.

Speaker 72 I don't know.

Speaker 33 I don't.

Speaker 138 I honestly just don't know.

Speaker 112 49.

Speaker 12 When the 15 boxes that Trump had provided reached NARA in January 2022, NARA reviewed the contents and determined that 14 of the boxes contained documents with classification markings.

Speaker 105 Specifically, as the FBI later determined, the boxes contained 197 documents with classification markings, of which 98 were marked secret, 30 were marked top secret, and the remainder were marked confidential.

Speaker 45 Some of those documents also contained SCI and SAP markings.

Speaker 131 50.

Speaker 7 On February 9th, 2022, NARA referred the discovery of classified documents in Trump's boxes to the Department of Justice for investigation.

Speaker 101 The FBI and Grand Jury Investigations.

Speaker 60 51.

Speaker 26 On March 30th, 2022, the FBI opened a criminal investigation.

Speaker 148 52.

Speaker 26 On April 26, 2022, a federal grand jury opened an investigation.

Speaker 73 The defendants' concealment of boxes.

Speaker 76 53.

Speaker 128 On May 11, 2022, the grand jury issued a subpoena, the May 11th subpoena, to the Office of Donald J.

Speaker 5 Trump, requiring the production of all documents with classification markings in the possession, custody, or control of Trump or the Office of Donald J.

Speaker 16 Trump.

Speaker 34 Two attorneys representing Trump, Trump Attorney 1 and Trump Attorney 2, informed Trump of the May 11th subpoena, and he authorized Trump Attorney 1 to accept service.

Speaker 140 54.

Speaker 87 On May 22, 2022, Nada entered the storage room at 3.47 p.m.

Speaker 56 and left approximately 34 minutes later, carrying one of Trump's boxes.

Speaker 60 55.

Speaker 163 On May 23, 2022, Trump met with Trump Attorney 1 and Trump Attorney 2 at the Mar-a-Lago Club to discuss the response to the May 11th subpoena.

Speaker 8 Trump Attorney 1 and Trump Attorney 2 told Trump that they needed to search for documents that would be responsive to the subpoena and provide a certification that there had been compliance with the subpoena.

Speaker 13 Trump, in sum and substance, made the following statements, among others, as memorialized by Trump Attorney 1.

Speaker 154 A, I don't want anybody looking.

Speaker 62 I don't want anybody looking through my boxes.

Speaker 39 I really don't.

Speaker 67 I don't want you looking through my boxes.

Speaker 38 B.

Speaker 156 Well, what if we, what happens if we just don't respond at all or don't play ball with them?

Speaker 38 C.

Speaker 129 Wouldn't it be better if we just told them we don't have anything here?

Speaker 38 D.

Speaker 103 Well, look, isn't it better if there are no documents?

Speaker 2 56.

Speaker 37 While meeting with Trump Attorney 1 and Trump Attorney 2 on May 23rd, Trump, in sum and substance, told the following story, as memorialized by Trump Attorney 1.

Speaker 22 Attorney, he was great.

Speaker 83 He did a great job.

Speaker 135 You know what?

Speaker 40 He said he said that it, that it was him, that he was the one who deleted all of her emails, the 30,000 emails, because they basically dealt with her scheduling and her going to the gym and her having beauty appointments.

Speaker 78 And he was great.

Speaker 79 And he, so she didn't get in any trouble because he said that he was the one who deleted them.

Speaker 74 Trump related the story more than once that day.

Speaker 93 57.

Speaker 72 On May 23rd, Trump also confirmed his understanding with Trump Attorney 1 that Trump Attorney 1 would return to the Mar-a-Lago Club on June 2nd to search for any documents with classification markings to produce in response to the May 11th subpoena.

Speaker 130 Trump Attorney 1 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.

Speaker 12 Trump indicated that he wanted to be at the Mar-a-Lago Club when Trump Attorney One returned to review his boxes on June 2nd, and that Trump would change his summer travel plans to do so.

Speaker 131 Trump told Trump Attorney 2 that Trump Attorney 2 did not need to be present for the review of boxes.

Speaker 101 58.

Speaker 23 After meeting with Trump Attorney 1 and Trump Attorney 2 on May 23, 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 2nd when Trump Attorney 1 returned to review the boxes.

Speaker 134 59.

Speaker 139 Between Trump's May 23rd meeting with Trump Attorney 1 and Trump Attorney 2 to discuss the May 11th subpoena, and June 2nd, when Trump Attorney 1 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 64 boxes from the storage room and brought them to Trump's residence, as set forth below.

Speaker 65 A.

Speaker 26 On May 24th, 2022, between 5.30 p.m.

Speaker 147 and 5.38 p.m., Nada removed three boxes from the storage room.

Speaker 38 B.

Speaker 52 On May 30th, 2022, at 9:08 a.m., Trump and Nada spoke by phone for approximately 30 seconds.

Speaker 94 Between 10.02 a.m.

Speaker 79 and 11.51 a.m., Nada removed a total of approximately 50 boxes from the storage room.

Speaker 106 C.

Speaker 26 On May 30th, 2022, at 12.33 p.m., a Trump family member texted Nada.

Speaker 21 Good afternoon, Walt.

Speaker 23 Happy Memorial Day.

Speaker 19 I saw you put boxes to POTUS room.

Speaker 68 Just FYI and I will tell him as well.

Speaker 29 Not sure how many he wants to take on Friday on the plane.

Speaker 67 We will not have a room for them.

Speaker 91 Plane will be full with luggage.

Speaker 90 Thank you, Nada replied.

Speaker 103 Good afternoon, ma'am.

Speaker 25 Thank you so much. I think he wanted to pick from them.

Speaker 123 I don't imagine him wanting to take the boxes.

Speaker 55 He told me to put them in the room and that he was going to talk to you about them.

Speaker 38 D.

Speaker 59 On June 1st, 2022, beginning at 12.52 p.m., Nada removed approximately 11 boxes from the storage room.

Speaker 63 60.

Speaker 144 On June 1st, 2022, Trump spoke with Trump Attorney 1 by phone and asked whether Trump Attorney 1 was coming to the Mara Lago Club the next day and for exactly what purpose.

Speaker 72 Trump Attorney 1 reminded Trump that Trump Attorney 1 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 11th subpoena had been complied with fully.

Speaker 36 61.

Speaker 139 On June 2nd, 2022, the day that Trump Attorney One was scheduled to review Trump's boxes in the storage room, Trump spoke with Nada on the phone at 9:29 a.m.

Speaker 26 for approximately 24 seconds.

Speaker 63 62.

Speaker 140 Later that day, between 12.33 p.m.

Speaker 164 and 12.52 p.m., Nada and Diolivera moved approximately 30 boxes from Trump's residence to the storage room.

Speaker 63 63.

Speaker 47 In sum, between May 23, 2022 and June 2, 2022, before Trump Attorney 1's review of Trump's boxes in the storage room, Nada, at Trump's direction, moved approximately 64 boxes from the storage room to Trump's residence, and Nada and Dioliveira brought to the storage room only approximately 30 boxes.

Speaker 108 Neither Trump nor Nada informed Trump Attorney One of this information, the false certification to the FBI and the grand jury, 64.

Speaker 102 On the afternoon of June 2nd, 2022, 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 11th subpoena.

Speaker 41 Trump met with Trump Attorney 1 before Trump Attorney 1 conducted the review.

Speaker 20 Nada escorted Trump Attorney 1 to the storage room, 65.

Speaker 140 Between 3.53 p.m.

Speaker 12 and 6.23 p.m., Trump Attorney One reviewed the contents of Trump's boxes in the storage room.

Speaker 55 Trump Attorney One located 38 documents with classification markings inside the boxes, which Trump Attorney One removed and placed in a Redweld folder.

Speaker 111 Trump Attorney One contacted Nada and asked him to bring clear duct tape to the storage room, which Nada did.

Speaker 74 Trump Attorney One used the clear duct tape to seal the Redweld folder with the documents with classification markings inside.

Speaker 151 66.

Speaker 101 After Trump Attorney 1 finished sealing the Redweld folder containing the documents with classification markings that he had found inside Trump's boxes, Nada took Trump Attorney 1 to a dining room in the Mar-a-Lago Club to meet with Trump.

Speaker 35 After Trump Attorney 1 confirmed that he was finished with his search of the storage room, Trump asked, Did you find anything?

Speaker 144 Is it bad?

Speaker 32 Good?

Speaker 51 67.

Speaker 7 Trump and Trump Attorney One then discussed what to do with the red weld 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.

Speaker 6 During that conversation, Trump made a plucking motion, as memorialized by Trump Attorney One.

Speaker 154 He made a funny motion as though, well, okay, why don't you take them with you to your hotel room?

Speaker 136 And if there's anything really bad in there, like, you know, pluck it out.

Speaker 17 And that was the motion that he made.

Speaker 2 He didn't say that.

Speaker 63 68.

Speaker 103 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 3rd, so that he could turn over the documents responsive to the May 11th subpoena.

Speaker 54 69.

Speaker 9 Also that evening, Trump Attorney 1 contacted another Trump attorney, Trump Attorney 3, 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 11th subpoena.

Speaker 97 Trump Attorney 3, who had no role in the review of Trump's boxes in the storage room, agreed.

Speaker 73 70.

Speaker 25 The next day, on June 3, 2022, at Trump Attorney 1's request, Trump Attorney 3 signed a certification as the custodian of records for the Office of Donald J.

Speaker 74 Trump and took it to the Mar-a-Lago Club to provide it to the Department of Justice and FBI.

Speaker 8 In the certification, Trump Attorney 3, who performed no search of Trump's boxes, had not reviewed the May 11th 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 diligent search was conducted of the boxes that were moved from the White House to Florida.

Speaker 38 B.

Speaker 130 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.

Speaker 122 Any and all responsive documents accompany this certification.

Speaker 55 71.

Speaker 17 These statements were false because, among other reasons, Trump had directed Nada to move boxes before Trump Attorney 1's June 2nd review, so that many boxes were not searched and many documents responsive to the May 11th subpoena could not be found, and in fact were not found, by Trump Attorney 1.

Speaker 66 72.

Speaker 20 Shortly after Trump Attorney 3 executed the false certification, on June 3, 2022, Trump Attorney 1 and Trump Attorney 3 met at the Mar-a-Lago Club with personnel from the Department of Justice and FBI.

Speaker 105 Trump Attorney 1 and Trump Attorney 3 turned over the Redweld folder containing documents with classification markings, as well as the false certification signed by Trump Attorney 3 as custodian of records.

Speaker 102 Trump, who had delayed his departure from the Mar-a-Lago Club, joined Trump Attorney 1 and Trump Attorney 3 for some of the meeting.

Speaker 93 Trump claimed to the Department of Justice and FBI that he was an open book.

Speaker 108 73.

Speaker 10 Earlier that same day, Nauda, Diolivera, and others loaded several of Trump's boxes along with other items on the aircraft that flew Trump and his family north for the summer.

Speaker 36 The attempt to delete security camera footage.

Speaker 51 74.

Speaker 9 On June 3rd, 2022, when FBI agents were at the Mar-a-Lago Club to collect the documents with classification markings from Trump Attorney 1 and Trump Attorney 3, the agents observed that there were surveillance cameras located near the storage room.

Speaker 51 75.

Speaker 130 On June 22, 2022, the Department of Justice emailed an attorney for Trump's business organization a draft grand jury subpoena requiring the production of certain security camera footage from the Mar-a-Lago Club, including footage from cameras on the ground floor, basement, where the storage room was located.

Speaker 73 76.

Speaker 18 On June 23, 2022, at 8.46 p.m., Trump called DiOliveira and they spoke for approximately 24 minutes.

Speaker 73 77.

Speaker 83 On Friday, June 24th, 2022, the Department of Justice emailed the attorney for Trump's business organization the final grand jury subpoena, which required the production of any and all surveillance records, videos, images, photographs, and/or CCTV from internal cameras at certain locations at the Mar-a-Lago Club, including on the ground floor, basement, from January 10th, 2022 to june 24th, 2022, 78.

Speaker 60 That same day, june 24th, 2022, at 1.25 p.m., Trump Attorney One spoke with Trump by phone regarding the subpoena for security camera footage.

Speaker 133 At 3.44 p.m., Nada received a text message from a coworker, Trump Employee 3, indicating that Trump wanted to see Nada.

Speaker 74 Less than two hours later, Nada, who was scheduled to travel with Trump to Illinois the next day, changed his travel schedule and began to make arrangements to go to Palm Beach, Florida instead.

Speaker 157 79.

Speaker 5 Nada provided inconsistent explanations to colleagues for his sudden travel to Florida.

Speaker 34 At 7.14 p.m.

Speaker 30 on June 24th, he texted one person that he would not be traveling with Trump the next day because he had a family emergency and used shushing emojis.

Speaker 154 At 9.48 p.m.

Speaker 11 that night, he texted a Secret Service agent that he had to check on a family member in Florida.

Speaker 78 And after he arrived in Florida on June 25th, he texted the same Secret Service agent that he was in Florida working.

Speaker 38 80.

Speaker 111 Around the same time on June 24th, that Nada was making his travel plans to go to Florida, Nada and DiOliveira contacted Trump Employee 4, who was the Director of Information Technology, IT, at the Mar-a-Lago Club, as follows.

Speaker 38 A.

Speaker 36 At 5.02 p.m., Nada sent text messages to Trump Employee 4 asking, Hey, bro, you around this weekend?

Speaker 38 B.

Speaker 74 At 5.05 p.m., Nada texted De Oliveira asking, Hey, brother, you working today?

Speaker 23 De Oliveira responded, Yes, I just left.

Speaker 84 Nada then called De Oliveira and they spoke for approximately two minutes.

Speaker 38 C.

Speaker 161 At 5.09 p.m., Trump employee 4 texted a response to Nada.

Speaker 13 I am local, entertaining some family that came to visit.

Speaker 42 What's up?

Speaker 161 Nada responded to Trump Employee 4. Okay, cool.

Speaker 63 No biggie just wanted to see if you wear around.

Speaker 24 Enjoy, bro.

Speaker 38 D.

Speaker 51 At 6.56 p.m., DiOlivera texted Trump.

Speaker 161 Employee 4.

Speaker 101 Hey buddy, how are you?

Speaker 79 Walter called me early, said it was trying to get in touch with you.

Speaker 122 I guess he's coming down tomorrow.

Speaker 40 I guess needs you for something.

Speaker 42 Trump employee 4 responded, he reached out, but he didn't say what he wanted.

Speaker 55 I told him I was local, but entertaining some family that came from NYC this weekend.

Speaker 9 He told me to no worries.

Speaker 17 Ah, at 6:58 p.m., Trump Employee 4 texted Nada, Bro, if you need me, I can get away for a few.

Speaker 53 Just let me know.

Speaker 33 Nada responded, sounds good.

Speaker 154 Thank you.

Speaker 20 81.

Speaker 33 On Saturday, June 25th, 2022, Nada traveled from Bedminster, New Jersey to Palm Beach, Florida.

Speaker 102 Prior to Nada's trip, Diolivera told a valet at the Mara Lago Club, Trump Employee 5, that Nada was coming down.

Speaker 13 Diolivea asked Trump Employee 5 not to tell anyone that Nada was coming down because Nada wanted the trip to remain secret.

Speaker 18 DiOliveira also told Trump Employee 5 that Nada wanted DiOliveira to talk to Trump Employee 4 to see how long camera footage was stored.

Speaker 148 82.

Speaker 52 Shortly after arriving in Palm Beach on the evening of June 25th, Nada went to the the Mara Lago Club and met with De Oliveira at 5.46 p.m.

Speaker 50 At the Mara Lago Club, Nada and Diolivera went to the security guard booth where surveillance video is displayed on monitors, walked with a flashlight through the tunnel where the storage room was located, and observed and pointed out surveillance cameras.

Speaker 143 83.

Speaker 18 On Monday, June 27, 2022, at 9.48 a.m., Diolivera walked to the IT office where Trump Employee 4 was working with another employee in the IT department.

Speaker 18 Dioliveira requested that Trump Employee 4 step away from the office so that Diolivera and Trump Employee 4 could talk.

Speaker 166 84.

Speaker 18 At 9.49 a.m., Trump Employee 4 and Diolivera left the area of the IT office together and walked through a basement tunnel.

Speaker 25 Diolivera took Trump Employee 4 to a small room known as an audio closet near the white and gold ballroom.

Speaker 18 Once inside the audio closet, Diolivera Diolivera and Trump Employee 4 had the following exchange.

Speaker 85 A.

Speaker 74 Diolivera told Trump Employee 4 that their conversation should remain between the two of them.

Speaker 38 B.

Speaker 161 Diolivera asked Trump employee 4 how many days the server retained footage.

Speaker 64 Trump employee 4 responded that he believed it was approximately 45 days.

Speaker 113 C.

Speaker 12 Diolivera told Trump Employee 4 that the boss wanted the server deleted.

Speaker 78 Trump employee 4 responded that he would not know how to do that and that he did not believe that he would have the rights to do that.

Speaker 133 Trump Employee 4 told DiOlivera that DiOlivera would have to reach out to another employee who was a supervisor of security for Trump's business organization.

Speaker 65 DiOlivera then insisted to Trump Employee 4 that the boss wanted the server deleted and asked, What are we going to do?

Speaker 48 85.

Speaker 93 At 10.14 a.m., DiOlivera texted Nada, who was still in Florida, Hey buddy, are you working today?

Speaker 164 DiOlivera then called Nada at 10.15 a.m., and they spoke for approximately one minute, 86.

Speaker 15 Later that day, at 1.06 p.m., Nada texted De Oliveira, who was at the Mar-a-Lago Club.

Speaker 109 On my way to you.

Speaker 67 Between 1.31 p.m.

Speaker 136 and 1.50 p.m., De Oliveira walked through the bushes on the northern edge of the Mar-a-Lago Club property to meet with Nada on the adjacent property, then walked back to the IT office that he had visited that morning, and then walked again through the bushes on the northern edge of the Mara Lago Club property to meet with Nada on the adjacent property.

Speaker 45 87.

Speaker 18 At 3:55 p.m., Trump called De Oliveira and they spoke for approximately three and a half minutes.

Speaker 39 The court authorized search of the Mara Lago Club.

Speaker 100 88.

Speaker 140 In July 2022, the FBI and grand jury obtained and reviewed surveillance video from the Mara Lago Club showing the movement of boxes set forth above.

Speaker 117 89.

Speaker 129 On August 8, 2022, the FBI executed a court-authorized search warrant at the Mara Lago Club.

Speaker 122 The search warrant authorized the FBI to search for and seize, among other things, all documents with classification markings.

Speaker 117 90.

Speaker 13 During the execution of the warrant at the Mara Lago Club, the FBI seized 102 documents with classification markings in Trump's Trump's office and the storage room.

Speaker 154 91.

Speaker 26 Just over two weeks after the FBI discovered classified documents in the storage room and Trump's office, on August 26, 2022, Nada called Trump Employee 5 and said words to the effect of, someone just wants to make sure Carlos is good.

Speaker 18 In response, Trump Employee 5 told Nada that De Oliveira was loyal and that De Oliveira would not do anything to affect his relationship with Trump.

Speaker 138 That same day, at Nada's request, Trump employee 5 confirmed in a signal chat group with Nada and the PAC representative that De Oliveira was loyal.

Speaker 18 That same day, Trump called Di Oliveira and told DiOlivera that Trump would get DiOliveira an attorney.

Speaker 25 Counts 1 through 32, 92.

Speaker 119 The general allegations of this superseding indictment are re-alleged and fully incorporated here by reference.

Speaker 117 93.

Speaker 112 On or about the dates set forth in the table below, in Palm Beach County, in the southern district of Florida.

Speaker 127 And elsewhere, the defendant, Donald J.

Speaker 66 Trump, having unauthorized possession of, access to, and control over documents relating to the national defense, did willfully retain the documents and fail to deliver them to the officer and employee of the United States entitled to receive them.

Speaker 115 That is, Trump, without authorization, retained at the Mar-a-Lago Club documents relating to the national defense, including the following.

Speaker 109 Count 33.

Speaker 124 Conspiracy to obstruct justice.

Speaker 152 94.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 40 The conspiracy and its objects.

Speaker 96 95.

Speaker 26 From on or about May 11th, 2022 through in or around August 2022, in Palm Beach County, in the Southern District of Florida and elsewhere, the defendants, Donald J.

Speaker 146 Trump, Waltine Nada, 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 USC.

Speaker 11 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 USC, and to corruptly alter, destroy, mutilate, and conceal a record, document, and other object from an official proceeding in violation of 18 USC.

Speaker 8 The purpose of the conspiracy.

Speaker 53 96.

Speaker 66 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.

Speaker 135 The manner and means of the conspiracy, 97.

Speaker 43 The manner and means by which the defendant sought to accomplish the objects and purpose of the conspiracy included, among other things, the following.

Speaker 38 A.

Speaker 9 Suggesting that Trump Attorney 1 falsely represent to the FBI and the grand jury that Trump did not have documents called for by the May 11th subpoena, B.

Speaker 101 Moving boxes of documents to conceal them from Trump Attorney 1, the FBI, and the grand jury, C.

Speaker 67 Suggesting that Trump Attorney 1 hide or destroy documents called for by the May 11th subpoena, D.

Speaker 110 Providing to the FBI and grand jury just some of the documents called for by the May 11th subpoena, while Trump claimed he was cooperating fully, E.

Speaker 50 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.

Speaker 36 F making false and misleading statements to the FBI and G, attempting to delete security camera footage from the Mara Lago Club to conceal the footage from the FBI and grand jury.

Speaker 152 Count 34.

Speaker 110 Withholding a document or record.

Speaker 109 98.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 117 99.

Speaker 26 From on or about May 11th, 2022 through in or around August 2022, in Palm Beach County, in the Southern District of Florida and elsewhere, the defendants, Donald J.

Speaker 143 Trump and Waltine Nauda, 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, one,

Speaker 20 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 contained documents with classification markings so that Trump Attorney One would not find the documents and produce them to a federal grand jury.

Speaker 109 Count 35.

Speaker 13 Corruptly concealing a document or record.

Speaker 116 100.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 116 101.

Speaker 26 From on or about May 11th, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida and elsewhere, the defendants, Donald J.

Speaker 151 Trump and Waltine Nada, 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.

Speaker 9 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.

Speaker 40 Count 36.

Speaker 55 Concealing a document in a federal investigation.

Speaker 83 102.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 116 103.

Speaker 110 From on or about May 11, 2022, through in or or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, Donald J.

Speaker 52 Trump and Walteen 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.

Speaker 32 That is, during a federal criminal investigation being conducted by the FBI, one, Trump and Nada hid, concealed, and covered up from the FBI Trump's continued possession of documents with classification markings at the Mar-a-Lago Club.

Speaker 141 And two, Trump caused a false certification to be submitted to the FBI.

Speaker 73 Count 37, scheme to conceal.

Speaker 116 104.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 116 105.

Speaker 26 From on or about May 11th, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, Donald J.

Speaker 146 Trump and Waltine 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.

Speaker 72 That is, during a federal grand jury investigation and a federal criminal investigation being conducted by the FBI, Trump and Nada hid and concealed from the grand jury and the FBI Trump's continued possession of documents with classification markings.

Speaker 109 Count 38.

Speaker 40 False statements and representations.

Speaker 25 106.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 25 107.

Speaker 112 On or about june third, 2022, in Palm Beach County, in the Southern District of Florida and elsewhere, the defendant, Donald J.

Speaker 159 Trump, in a matter within the jurisdiction of the judicial branch and the 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 3.

Speaker 38 A.

Speaker 149 A diligent search was conducted of the boxes that were moved from the White House to Florida.

Speaker 38 B.

Speaker 97 This search was conducted after receipt of the subpoena in order to locate any and all documents that are responsive to the subpoena.

Speaker 96 And C.

Speaker 95 Any and all responsive documents accompany this certification.

Speaker 116 108.

Speaker 73 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 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.

Speaker 138 Trump Attorney One's search would not and did not locate all documents responsive to the May 11th subpoena, and all responsive documents were not provided to the FBI and the grand jury with the certification.

Speaker 105 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 8th, 2020.

Speaker 83 Count 39.

Speaker 127 False statements and representations.

Speaker 116 109.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 116 110.

Speaker 67 On May 26th, 2022, Nada participated in a voluntary interview with the FBI.

Speaker 30 During the interview, the FBI explained to Nada that the FBI was investigating how classified documents had been kept at the Mara Lago Club, and the FBI asked Nada questions about the location and movement of Trump's boxes before Trump provided 15 boxes to NARA on January 17th, 2022.

Speaker 101 Nada was represented by counsel, and the FBI advised Nada that the interview was voluntary and that he could leave at any time.

Speaker 51 The FBI also advised Nada that it was a criminal offense to lie to the FBI.

Speaker 104 The interview was recorded.

Speaker 33 111.

Speaker 77 On or about May 26, 2022, in Palm Beach County, in the Southern District of Florida and elsewhere, the defendant, Walteen Nada, 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.

Speaker 101 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.

Speaker 167 Question.

Speaker 139 Does any are you aware of any boxes being brought to his home, his suite?

Speaker 53 Answer no.

Speaker 167 Question.

Speaker 102 All right.

Speaker 20 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 two needed you to answer, correct.

Speaker 167 Question.

Speaker 143 To take them. Okay.

Speaker 167 Question.

Speaker 154 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?

Speaker 86 Answer, mm-hmm.

Speaker 28 Question: Do you have any information that could, that would, that could help us understand, like, where they were kept, how they were kept, were they secured, were they locked?

Speaker 54 Something that makes the intelligence community feel better about these things, you know?

Speaker 30 Answer.

Speaker 129 I wish, I wish I could tell you.

Speaker 72 I don't know.

Speaker 138 I don't, I honestly just don't know.

Speaker 167 Question.

Speaker 114 And what so, so you only saw the 15 boxes, 15, 17 boxes?

Speaker 150 Answer yes.

Speaker 167 Question.

Speaker 150 The day of the move?

Speaker 108 Even they just showed up that day?

Speaker 113 Answer.

Speaker 126 They were in Pine Hall.

Speaker 148 Trump employee two.

Speaker 158 Just asked me, hey, can we move some boxes?

Speaker 89 And I was like, okay.

Speaker 167 Question.

Speaker 101 So you didn't know, had no idea how they got there before?

Speaker 103 Answer no.

Speaker 116 112.

Speaker 93 The underscored statements and representations above were false, as Nada knew, because one, Nada did in fact know that the boxes in Pine Hall had come from the storage room, as Nada himself, with the assistance of Trump employee two, had moved the boxes from the storage room to Pine Hall, and two, Nada had observed the boxes in and moved them to various locations at the Mar-a-Lago Club.

Speaker 152 Count 40.

Speaker 6 Altering, destroying, mutilating, or concealing an object.

Speaker 116 113.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 25 114.

Speaker 26 From on or about june 22nd, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, Donald J.

Speaker 9 Trump, Waltine Nada, 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 availability for use in an official proceeding.

Speaker 36 That is, Trump, Nada, and DiOliveira 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.

Speaker 152 Count 41.

Speaker 6 Corruptly altering, destroying, mutilating, or concealing a document, record, or other object.

Speaker 17 115.

Speaker 119 The general allegations of this superseding indictment are re-alleged and fully incorporated here by reference.

Speaker 35 116.

Speaker 26 From on or about june 22nd, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida and elsewhere, the defendants, Donald J.

Speaker 82 Trump, Waltine Nada, 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.

Speaker 97 That is, Trump, Nada, and De Oliveira requested that Trump employee Ford delete security camera footage at the Mar-a-Lago Club to prevent the footage from being provided to a federal grand jury.

Speaker 127 Count 42, false statements and representations.

Speaker 116 117.

Speaker 119 The general allegations of this superseding indictment are realleged and fully incorporated here by reference.

Speaker 17 118.

Speaker 55 On January 13, 2023, De Oliveira participated participated in a voluntary interview with the FBI at de Oliveira's residence.

Speaker 102 During the interview, the FBI explained to de Oliveira that the FBI was investigating how classified documents had been kept at the Mar-a-Lago Club, and the FBI asked de Oliveira questions about the location and movement of Trump's boxes and other items.

Speaker 8 De Oliveira was advised by the FBI that the interview was voluntary and that he could tell the agents to leave at any time.

Speaker 101 The FBI also advised de Oliveira that it was a criminal offense to lie to the FBI.

Speaker 104 The interview was recorded.

Speaker 25 119.

Speaker 77 On or about January 13th, 2023, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant, Carlos de Oliveira, 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.

Speaker 101 That is, in a voluntary interview during a federal criminal investigation being conducted by the FBI, De Oliveira was asked the following questions and gave the following false answers.

Speaker 167 Question.

Speaker 39 When, after the end of the presidency, boxes arrived to Mar-a-Lago, were you part of any group to help?

Speaker 87 Answer: No.

Speaker 103 No.

Speaker 167 Question.

Speaker 147 Unload them and move them?

Speaker 47 Answer.

Speaker 72 No.

Speaker 167 Question.

Speaker 140 Do you were you?

Speaker 91 Do you even know like or were you even there or aware that boxes were answer?

Speaker 38 No.

Speaker 167 Question.

Speaker 8 Like all this stuff was being moved in?

Speaker 42 Answer, never saw anything.

Speaker 30 Question, okay.

Speaker 27 Answer, yeah.

Speaker 154 And then, question,

Speaker 56 even his personal stuff, like his clothes.

Speaker 86 Answer, never.

Speaker 167 Question.

Speaker 116 And furniture, nothing?

Speaker 123 Answer, never saw nothing.

Speaker 167 Question, okay.

Speaker 17 So you don't know where items would have been stored as soon as he moved back to Mar-a-Lago.

Speaker 116 Answer no, 120.

Speaker 164 The underscored statements and representations above were false, as De Oliveira knew, because de Oliveira had personally observed and helped move Trump's boxes when they arrived at the Mar-a-Lago Club in January 2021.

Speaker 15 Jack Smith, Special Counsel, United States Department of Justice.

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