Page:United States of America v. Donald J. Trump and Waltine Nauta.pdf/39



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

89. 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, 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; that is—during a federal grand jury investigation and a federal criminal investigation being conducted by the FBI, TRUMP and NAUTA hid and concealed from the grand jury and the FBI TRUMP’s continued possession of documents with classification markings.