Page:United States of America v. Donald J. Trump and Waltine Nauta.pdf/26

 Subpoena, and had not reviewed the contents of the Redweld folder—stated, among other things, that “[b]ased 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.”

70. These statements were false because, among other reasons, TRUMP had directed NAUTA to move boxes before Trump Attorney 1’s June 2 review, so that many boxes were not searched and many documents responsive to the May 11 Subpoena could not be found—and in fact were not found—by Trump Attorney 1.

71. 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. 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. 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. TRUMP claimed to the Department of Justice and FBI that he was “an open book.”

72. Earlier that same day, NAUTA and others loaded several of TRUMP’s boxes along with other items on aircraft that flew TRUMP and his family north for the summer.

73. In July 2022, the FBI and grand jury obtained and reviewed surveillance video from The Mar-a-Lago Club showing the movement of boxes set forth above.