been produced—while knowing that, in fact, not all such documents had been produced; and
f. attempting to delete security camera footage at The Mar-a-Lago Club to conceal information from the FBI and grand jury.
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-Conspirators
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.
10. Beginning in January 2022, Defendant CARLOS DE OLIVEIRA was employed as the property manager at The Mar-a-Lago Club. Prior to holding the position of property manager, DE OLIVEIRA was employed as a valet at The Mar-a-Lago Club.
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