Page:United States v. Trump superseding indictment.pdf/24

 Club so that Trump Attorney 1 could have a custodian of records certify that the May 11 subpoena had been complied with fully.

61. On June 2, 2022, the day that Trump Attorney 1 was scheduled to review TRUMP’s boxes in the Storage Room, TRUMP spoke with NAUTA on the phone at 9:29 a.m. for approximately 24 seconds.

62. Later that day, between 12:33 p.m. and 12:52 p.m., NAUTA and DE OLIVEIRA moved approximately 30 boxes from TRUMP’s residence to the Storage Room.

63. In sum, between May 23, 2022, and June 2, 2022, before Trump Attorney 1’s review of TRUMP’s boxes in the Storage Room, NAUTA—at TRUMP’s direction—moved approximately 64 boxes from the Storage Room to TRUMP’s residence, and NAUTA and DE OLIVEIRA brought to the Storage Room only approximately 30 boxes. Neither TRUMP nor NAUTA informed Trump Attorney 1 of this information.

64. On the afternoon of June 2, 2022, as TRUMP had been informed, Trump Attorney 1 arrived at The Mar-a-Lago Club to review TRUMP’s boxes to look for documents with classification markings in response to the May 11 Subpoena. TRUMP met with Trump Attorney 1 before Trump Attorney 1 conducted the review. NAUTA escorted Trump Attorney 1 to the Storage Room.

65. Between 3:53 p.m. and 6:23 p.m., Trump Attorney 1 reviewed the contents of TRUMP’s boxes in the Storage Room. Trump Attorney 1 located 38 documents with classification markings inside the boxes, which Trump Attorney 1 removed and placed in a Redweld folder. Trump Attorney 1 contacted NAUTA and asked him to bring clear duct tape to the Storage Room, which NAUTA did. Trump Attorney 1 used the clear duct tape to seal the Redweld folder with the documents with classification markings inside.