Page:United States v. Trump superseding indictment.pdf/17

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Case 9:23-cr-80101-AMC
Document 85
Entered on FLSD Docket 07/27/2023
Page 17 of 60

Country A. The document that TRUMP possessed and showed on July 21, 2021, is charged as Count 32 in this Superseding Indictment.

36. In August or September 2021, when he was no longer president, TRUMP met in his office at The Bedminster Club with a representative of his political action committee (the “PAC Representative”). During the meeting, TRUMP commented that an ongoing military operation in Country B was not going well. TRUMP showed the PAC Representative a classified map of Country B and told the PAC Representative that he should not be showing the map to the PAC Representative and to not get too close. The PAC Representative did not have a security clearance or any need-to-know classified information about the military operation.

37. On February 16, 2017, four years before TRUMP’s disclosures of classified information set forth above, TRUMP said at a press conference:

The first thing I thought of when I heard about it is, how does the press get this information that’s classified? How do they do it? You know why? Because it’s an illegal process, and the press should be ashamed of themselves. But more importantly, the people that gave out the information to the press should be ashamed of themselves. Really ashamed.

TRUMP’s Production of 15 Cardboard Boxes to the
National Archives and Records Administration

38. Beginning in May 2021, the National Archives and Records Administration (“NARA”), which was responsible for archiving presidential records, repeatedly demanded that TRUMP turn over presidential records that he had kept after his presidency. On multiple occasions, beginning in June, NARA warned TRUMP through his representatives that if he did not comply, it would refer the matter of the missing records to the Department of Justice.

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