8. As a result of TRUMP’s retention of classified documents after his presidency and refusal to return them, hundreds of classified documents were not recovered by the United States government until 2022, as follows:
a. On January 17, nearly one year after TRUMP left office, and after months of demands by the National Archives and Records Administration for TRUMP to provide all missing presidential records, TRUMP provided only 15 boxes, which contained 197 documents with classification markings.
b. On June 3, in response to a grand jury subpoena demanding the production of all documents with classification markings, TRUMP’s attorney provided to the FBI 38 more documents with classification markings.
c. On August 8, pursuant to a court-authorized search warrant, the FBI recovered from TRUMP’s office and a storage room at The Mar-a-Lago Club 102 more documents with classification markings.
TRUMP’s Co-Conspirator
9. Defendant NAUTA was a member of the United States Navy stationed as a valet in the White House during TRUMP’s presidency. Beginning in August 2021, NAUTA became an executive assistant in The Office of Donald J. Trump and served as TRUMP’s personal aide or “body man.” NAUTA reported to TRUMP, worked closely with TRUMP, and traveled with TRUMP.
The Mar-a-Lago Club
10. The Mar-a-Lago Club was located on South Ocean Boulevard in Palm Beach, Florida, and included TRUMP’s residence, more than 25 guest rooms, two ballrooms, a spa, a gift store, exercise facilities, office space, and an outdoor pool and patio. As of January 2021, The Mar-a-Lago Club had hundreds of members and was staffed by more than 150 full-time, part-time, and temporary employees.
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