w:Jack Smith

“ Pursuant to Executive Order 13526, information classified at any level could be lawfully accessed only by persons determined by an appropriate United States government official to be eligible for access to classified information and who had signed an approved non-disclosure agreement, who received a security clearance, and who had a “need-to-know” the classified information. After his presidency, TRUMP was not authorized to possess or retain classified documents. ”

“ In May 2021, TRUMP caused some of his boxes to be brought to his summer residence at The Bedminster Club. Like The Mar-a-Lago Club, after TRUMP’s presidency, The Bedminster Club was not an authorized location for the storage, possession, review, display, or discussion of classified documents. ”

“ The National Geospatial Intelligence Agency was a combat support agency within DoD responsible for the exploitation and analysis of imagery, imagery intelligence, and geospatial information in support of the national security objectives of the United States and the geospatial intelligence requirements of DoD, the Department of State, and other federal agencies. ”

“ Trump Attorney 1 and Trump Attorney 2 told TRUMP that they needed to search for documents that would be responsive to the subpoena and provide a certification that there had been compliance with the subpoena. TRUMP, in sum and substance, made the following statements, among others, as memorialized by Trump Attorney 1:
a. I don’t want anybody looking, I don’t want anybody looking through my boxes, I really don’t, I don’t want you looking through my boxes.
b. Well what if we, what happens if we just don’t respond at all or don’t play ball with them? ”

“ 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, DONALD J. TRUMP and
WALTINE NAUTA, did knowingly conceal, cover up, falsify, and make a false entry in any record, document, and tangible object with the intent to impede, obstruct, and influence the investigation and proper administration of any matter within the jurisdiction of a department and agency of the United States, and in relation to and contemplation of any such matter ”

“ The Purpose of the Conspiracy
80. The purpose of the conspiracy was for TRUMP to keep classified documents he had taken with him from the White House and to hide and conceal them from a federal grand jury. ”

“ Such access is particularly inappropriate when former officials have transitioned into highly partisan positions and seek to use real or perceived access to sensitive information to validate their political attacks. ”

“ Well, with [the Senior Military Official] —uh, let me see that, I’ll show you an example. He said that I wanted to attack [Country A] . Isn’t it amazing? I have a big pile of papers, this thing just came up. Look. ”