SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE
STATE OF NEW YORK -against- DONALD J. TRUMP, Defendant. THE GRAND JURY OF
THE COUNTY OF NEW YORK, by this indictment, accuses the defendant of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of
Penal Law §175.10, committed as follows: The defendant, in the County of
New York and elsewhere, on or about February 14, 2017, with intent to
defraud and intent to commit another crime and aid and conceal the
commission thereof, made and caused a false entry in the business records
of an enterprise, to wit, an invoice from Michael Cohen dated February 14,
2017, marked as a record of the Donald J. Trump Revocable Trust, and kept
and maintained by the Trump Organization. SECOND COUNT: AND THE GRAND JURY
AFORESAID, by this indictment, further accuses the defendant of the crime
of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal
Law §175.10, committed as follows: The defendant, in the County of New York
and elsewhere, on or about February 14, 2017, with intent to defraud and
intent to commit another crime and aid and conceal the commission thereof,
made and caused a false entry in the business records of an enterprise, to
wit, an entry in the Detail General Ledger for the Donald J. Trump
Revocable Trust, bearing voucher number 842457, and kept and maintained by
the Trump Organization.

p. 2



THIRD COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE
FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about February
14, 2017, with intent to defraud and intent to commit another crime and aid
and conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, an entry in the Detail General
Ledger for the Donald J. Trump Revocable Trust, bearing voucher number
842460, and kept and maintained by the Trump Organization. FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the
defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE,
in violation of Penal Law §175.10, committed as follows: The defendant, in
the County of New York and elsewhere, on or about February 14, 2017, with
intent to defraud and intent to commit another crime and aid and conceal
the commission thereof, made and caused a false entry in the business
records of an enterprise, to wit, a Donald J. Trump Revocable Trust Account
check and check stub dated February 14, 2017, bearing check number 000138,
and kept and maintained by the Trump Organization. FIFTH COUNT: AND THE
GRAND JURY AFORESAID, by this indictment, further accuses the defendant of
the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation
of Penal Law §175.10, committed as follows:

The defendant, in the County of New York and elsewhere, on or about March
16, 2017 through March 17, 2017, with intent to defraud and intent to
commit another crime and aid and conceal the commission thereof, made and
caused a false entry in the business records of an enterprise, to wit, an
invoice from Michael Cohen dated February 16, 2017 and transmitted on or
about March 16, 2017, marked as a record of the Donald J. Trump Revocable
Trust, and kept and maintained by the Trump Organization. SIXTH COUNT: AND
THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in
violation of Penal Law §175.10, committed as follows: The defendant, in the
County of New York and elsewhere, on or about March 17, 2017, with intent
to defraud and intent to commit another crime and aid and conceal the
commission thereof, made and caused a false entry in the business records
of an enterprise, to wit, an entry in the Detail General Ledger for the
Donald J. Trump Revocable Trust, bearing voucher number 846907, and kept
and maintained by the Trump Organization. SEVENTH COUNT: AND THE GRAND JURY
AFORESAID, by this indictment, further accuses the defendant of the crime
of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal
Law §175.10, committed as follows:

he defendant, in the County of New York and elsewhere, on or about March
17, 2017, with intent to defraud and intent to commit another crime and aid
and conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, a Donald J. Trump Revocable
Trust Account check and check stub dated March 17, 2017, bearing check
number 000147, and kept and maintained by the Trump Organization. EIGHTH
COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further accuses
the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST
DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about April 13,
2017 through June 19, 2017, with intent to defraud and intent to commit
another crime and aid and conceal the commission thereof, made and caused a
false entry in the business records of an enterprise, to wit, an invoice
from Michael Cohen dated April 13, 2017, marked as a record of Donald J.
Trump, and kept and maintained by the Trump Organization. NINTH COUNT: AND
THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant
of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in
violation of Penal Law §175.10, committed as follows: The defendant, in the
County of New York and elsewhere, on or about June 19, 2017, with intent to
defraud and intent to commit another crime and aid and conceal the
commission thereof, made and caused a false entry in the business records
of an enterprise, to wit, an entry in the Detail General Ledger for Donald
J. Trump, bearing voucher number 858770, and kept and maintained by the
Trump Organization.

TENTH COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE
FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about June 19,
2017, with intent to defraud and intent to commit another crime and aid and
conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, a Donald J. Trump account check
and check stub dated June 19, 2017, bearing check number 002740, and kept
and maintained by the Trump Organization. ELEVENTH COUNT: AND THE GRAND
JURY AFORESAID, by this indictment, further accuses the defendant of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of
Penal Law §175.10, committed as follows: The defendant, in the County of
New York and elsewhere, on or about May 22, 2017, with intent to defraud
and intent to commit another crime and aid and conceal the commission
thereof, made and caused a false entry in the business records of an
enterprise, to wit, an invoice from Michael Cohen dated May 22, 2017,
marked as a record of Donald J. Trump, and kept and maintained by the Trump
Organization. TWELFTH COUNT: AND THE GRAND JURY AFORESAID, by this
indictment, further accuses the defendant of the crime of FALSIFYING
BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10,
committed as follows:

The defendant, in the County of New York and elsewhere, on or about May 22,
2017, with intent to defraud and intent to commit another crime and aid and
conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, an entry in the Detail General
Ledger for Donald J. Trump, bearing voucher number 855331, and kept and
maintained by the Trump Organization. THIRTEENTH COUNT: AND THE GRAND JURY
AFORESAID, by this indictment, further accuses the defendant of the crime
of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal
Law §175.10, committed as follows: The defendant, in the County of New York
and elsewhere, on or about May 23, 2017, with intent to defraud and intent
to commit another crime and aid and conceal the commission thereof, made
and caused a false entry in the business records of an enterprise, to wit,
a Donald J. Trump account check and check stub dated May 23, 2017, bearing
check number 002700, and kept and maintained by the Trump Organization.
FOURTEENTH COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE
FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about June 16,
2017 through June 19, 2017, with intent to defraud and intent to commit
another crime and aid and conceal the commission thereof, made and caused a
false entry in the business records of an enterprise, to wit, an invoice
from Michael Cohen dated June 16, 2017, marked as a record of Donald J.
Trump, and kept and maintained by the Trump Organization.

FIFTEENTH COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE
FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about June 19,
2017, with intent to defraud and intent to commit another crime and aid and
conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, an entry in the Detail General
Ledger for Donald J. Trump, bearing voucher number 858772, and kept and
maintained by the Trump Organization. SIXTEENTH COUNT: AND THE GRAND JURY
AFORESAID, by this indictment, further accuses the defendant of the crime
of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal
Law §175.10, committed as follows: The defendant, in the County of New York
and elsewhere, on or about June 19, 2017, with intent to defraud and intent
to commit another crime and aid and conceal the commission thereof, made
and caused a false entry in the business records of an enterprise, to wit,
a Donald J. Trump account check and check stub dated June 19, 2017, bearing
check number 002741, and kept and maintained by the Trump Organization.
SEVENTEENTH COUNT: AND THE GRAND JURY AFORESAID, by this indictment,
further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as
follows:

The defendant, in the County of New York and elsewhere, on or about July
11, 2017, with intent to defraud and intent to commit another crime and aid
and conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, an invoice from Michael Cohen
dated July 11, 2017, marked as a record of Donald J. Trump, and kept and
maintained by the Trump Organization. EIGHTEENTH COUNT: AND THE GRAND JURY
AFORESAID, by this indictment, further accuses the defendant of the crime
of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal
Law §175.10, committed as follows: The defendant, in the County of New York
and elsewhere, on or about July 11, 2017, with intent to defraud and intent
to commit another crime and aid and conceal the commission thereof, made
and caused a false entry in the business records of an enterprise, to wit,
an entry in the Detail General Ledger for Donald J. Trump, bearing voucher
number 861096, and kept and maintained by the Trump Organization.
NINETEENTH COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE
FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about July 11,
2017, with intent to defraud and intent to commit another crime and aid and
conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, a Donald J. Trump account check
and check stub dated July 11, 2017, bearing check number 002781, and kept
and maintained by the Trump Organization.

TWENTIETH COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further
accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE
FIRST DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about August 1,
2017, with intent to defraud and intent to commit another crime and aid and
conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, an invoice from Michael Cohen
dated August 1, 2017, marked as a record of Donald J. Trump, and kept and
maintained by the Trump Organization. TWENTY-FIRST COUNT: AND THE GRAND
JURY AFORESAID, by this indictment, further accuses the defendant of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of
Penal Law §175.10, committed as follows: The defendant, in the County of
New York and elsewhere, on or about August 1, 2017, with intent to defraud
and intent to commit another crime and aid and conceal the commission
thereof, made and caused a false entry in the business records of an
enterprise, to wit, an entry in the Detail General Ledger for Donald J.
Trump, bearing voucher number 863641, and kept and maintained by the Trump
Organization. TWENTY-SECOND COUNT: AND THE GRAND JURY AFORESAID, by this
indictment, further accuses the defendant of the crime of FALSIFYING
BUSINESS RECORDS IN THE The defendant, in the County of New York and
elsewhere, on or about August 1, 2017, with intent to defraud and intent to
commit another crime and aid and conceal the commission thereof, made and
caused a false entry in the business records of an enterprise, to wit, a
Donald J. Trump account check and check stub dated August 1, 2017, bearing
check number 002821, and kept and maintained by the Trump Organization.
TWENTY-THIRD COUNT: AND THE GRAND JURY AFORESAID, by this indictment,
further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as
follows: The defendant, in the County of New York and elsewhere, on or
about September 11, 2017, with intent to defraud and intent to commit
another crime and aid and conceal the commission thereof, made and caused a
false entry in the business records of an enterprise, to wit, an invoice
from Michael Cohen dated September 11, 2017, marked as a record of Donald
J. Trump, and kept and maintained by the Trump Organization. TWENTY-FOURTH
COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further accuses
the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST
DEGREE, in violation of Penal Law §175.10, committed as follows: The
defendant, in the County of New York and elsewhere, on or about September
11, 2017, with intent to defraud and intent to commit another crime and aid
and conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, an entry in the Detail General
Ledger for Donald J. Trump, bearing voucher number 868174, and kept and
maintained by the Trump Organization. FIRST DEGREE, in violation of Penal
Law §175.10, committed as follows:

TWENTY-FIFTH COUNT: AND THE GRAND JURY AFORESAID, by this indictment,
further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as
follows: The defendant, in the County of New York and elsewhere, on or
about September 12, 2017, with intent to defraud and intent to commit
another crime and aid and conceal the commission thereof, made and caused a
false entry in the business records of an enterprise, to wit, a Donald J.
Trump account check and check stub dated September 12, 2017, bearing check
number 002908, and kept and maintained by the Trump Organization.
TWENTY-SIXTH COUNT: AND THE GRAND JURY AFORESAID, by this indictment,
further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as
follows: The defendant, in the County of New York and elsewhere, on or
about October 18, 2017, with intent to defraud and intent to commit another
crime and aid and conceal the commission thereof, made and caused a false
entry in the business records of an enterprise, to wit, an invoice from
Michael Cohen dated October 18, 2017, marked as a record of Donald J.
Trump, and kept and maintained by the Trump Organization. TWENTY-SEVENTH
COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further accuses
the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST
DEGREE, in violation of Penal Law §175.10, committed as follows:

The defendant, in the County of New York and elsewhere, on or about October
18, 2017, with intent to defraud and intent to commit another crime and aid
and conceal the commission thereof, made and caused a false entry in the
business records of an enterprise, to wit, an entry in the Detail General
Ledger for Donald J. Trump, bearing voucher number 872654, and kept and
maintained by the Trump Organization. TWENTY-EIGHTH COUNT: AND THE GRAND
JURY AFORESAID, by this indictment, further accuses the defendant of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of
Penal Law §175.10, committed as follows: The defendant, in the County of
New York and elsewhere, on or about October 18, 2017, with intent to
defraud and intent to commit another crime and aid and conceal the
commission thereof, made and caused a false entry in the business records
of an enterprise, to wit, a Donald J. Trump account check and check stub
dated October 18, 2017, bearing check number 002944, and kept and
maintained by the Trump Organization. TWENTY-NINTH COUNT: AND THE GRAND
JURY AFORESAID, by this indictment, further accuses the defendant of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of
Penal Law §175.10, committed as follows: The defendant, in the County of
New York and elsewhere, on or about November 20, 2017, with intent to
defraud and intent to commit another crime and aid and conceal the
commission thereof, made and caused a false entry in the business records
of an enterprise, to wit, an invoice from Michael Cohen dated November 20,
2017, marked as a THIRTIETH COUNT: AND THE GRAND JURY AFORESAID, by this
indictment, further accuses the defendant of the crime of FALSIFYING
BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10,
committed as follows: The defendant, in the County of New York and
elsewhere, on or about November 20, 2017, with intent to defraud and intent
to commit another crime and aid and conceal the commission thereof, made
and caused a false entry in the business records of an enterprise, to wit,
an entry in the Detail General Ledger for Donald J. Trump, bearing voucher
number 876511, and kept and maintained by the Trump Organization.
THIRTY-FIRST COUNT: AND THE GRAND JURY AFORESAID, by this indictment,
further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as
follows: The defendant, in the County of New York and elsewhere, on or
about November 21, 2017, with intent to defraud and intent to commit
another crime and aid and conceal the commission thereof, made and caused a
false entry in the business records of an enterprise, to wit, a Donald J.
Trump account check and check stub dated November 21, 2017, bearing check
number 002980, and kept and maintained by the Trump Organization.
THIRTY-SECOND COUNT: AND THE GRAND JURY AFORESAID, by this indictment,
further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS
IN THE FIRST DEGREE, in violation of Penal Law §175.10, committed as
follows: record of Donald J. Trump, and kept and maintained by the Trump
Organization.

The defendant, in the County of New York and elsewhere, on or about
December 1, 2017, with intent to defraud and intent to commit another crime
and aid and conceal the commission thereof, made and caused a false entry
in the business records of an enterprise, to wit, an invoice from Michael
Cohen dated December 1, 2017, marked as a record of Donald J. Trump, and
kept and maintained by the Trump Organization. THIRTY-THIRD COUNT: AND THE
GRAND JURY AFORESAID, by this indictment, further accuses the defendant of
the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation
of Penal Law §175.10, committed as follows: The defendant, in the County of
New York and elsewhere, on or about December 1, 2017, with intent to
defraud and intent to commit another crime and aid and conceal the
commission thereof, made and caused a false entry in the business records
of an enterprise, to wit, an entry in the Detail General Ledger for Donald
J. Trump, bearing voucher number 877785, and kept and maintained by the
Trump Organization. THIRTY-FOURTH COUNT: AND THE GRAND JURY AFORESAID, by
this indictment, further accuses the defendant of the crime of FALSIFYING
BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law §175.10,
committed as follows: The defendant, in the County of New York and
elsewhere, on or about December 5, 2017, with intent to defraud and intent
to commit another crime and aid and conceal the commission thereof, made
and caused a false entry in the business records of an enterprise, to wit,
a Donald J

Trump account check and check stub dated December 5, 2017, bearing check
number 003006, and kept and maintained by the Trump Organization. ALVIN L.
BRAGG, JR. District Attorney

GJ #8-5 Filed: NA No. THE PEOPLE OF THE STATE OF NEW YORK -against- DONALD
J. TRUMP, Defendant. INDICTMENT FALSIFYING BUSINESS RECORDS IN THE FIRST
DEGREE, P.L. §175.10, 34 Cts ALVIN L. BRAGG JR., District Attorney A True
Bill Foreperson ADJOURNED TO PART _______ ON ________



 kr irs 5423

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