Page:United States of America v. Donald J. Trump and Waltine Nauta.pdf/17

 Representative”). During the meeting, TRUMP commented that an ongoing military operation in Country B was not going well. TRUMP showed the PAC Representative a classified map of Country B and told the PAC Representative that he should not be showing the map to the PAC Representative and to not get too close. The PAC Representative did not have a security clearance or any need-to-know classified information about the military operation.

36. On February 16, 2017, four years before TRUMP’s disclosures of classified information set forth above, TRUMP said at a press conference:

37. Beginning in May 2021, 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.

38. Between November 2021 and January 2022, NAUTA and Trump Employee 2——at TRUMP’s direction—brought boxes from the Storage Room to TRUMP’s residence for TRUMP to review.

39. 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. Trump Employee 2 provided TRUMP the photograph so that TRUMP