Page:United States of America v. Donald J. Trump and Waltine Nauta.pdf/25

 65. After Trump Attorney 1 finished sealing the Redweld folder containing the documents with classification markings that he had found inside TRUMP’s boxes, NAUTA took Trump Attorney 1 to a dining room in The Mar-a-Lago Club to meet with TRUMP. After Trump Attorney 1 confirmed that he was finished with his search of the Storage Room, TRUMP asked, “Did you find anything? ... Is it bad? Good?”

66. TRUMP and Trump Attorney 1 then discussed what to do with the Redweld folder containing documents with classification markings and whether Trump Attorney 1 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 1:

67. That evening, Trump Attorney 1 contacted the Department of Justice and requested that an FBI agent meet him at The Mar-a-Lago Club the next day, June 3, so that he could turn over the documents responsive to the May 11 Subpoena.

68. 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 11 Subpoena. Trump Attorney 3, who had no role in the review of TRUMP’s boxes in the Storage Room, agreed.

69. 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. 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 3—who performed no search of TRUMP’s boxes, had not reviewed the May 11