Page:United States of America v. Donald J. Trump and Waltine Nauta.pdf/38



86. The General Allegations of this Indictment are re-alleged and fully incorporated here by reference.

87. From on or about May 11, 2022, through in or around August 2022, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, 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, (1) TRUMP and NAUTA hid, concealed, and covered up from the FBI TRUMP’s continued possession of documents with classification markings at The Mar-a-Lago Club; and (2) TRUMP caused a false certification to be submitted to the FBI.