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Case 9:23-cr-80101-AMC
Document 3
Entered on FLSD Docket 06/08/2023
Page 28 of 49
COUNTS 1-31
Willful Retention of National Defense Information
(18 U.S.C. § 793(e))
76. The General Allegations of this Indictment are re-alleged and fully incorporated here by reference.
77. On or about the dates set forth in the table below, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant, DONALD J. TRUMP, having unauthorized possession of, access to, and control over documents relating to the national defense, did willfully retain the documents and fail to deliver them to the officer and employee of the United States entitled to receive them; that is—TRUMP, without authorization, retained at The Mar-a-Lago Club documents relating to the national defense, including the following:
| Count | Date of Offense / Classification Marking / Document Description |
|---|---|
| 1 | January 20, 2021 – August 8, 2022 |
| TOP SECRET//NOFORN//SPECIAL HANDLING | |
| Document dated May 3, 2018, concerning White House intelligence briefing related to various foreign countries | |
| 2 | January 20, 2021 – August 8, 2022 |
| TOP SECRET//SI//NOFORN//SPECIAL HANDLING | |
| Document dated May 9, 2018, concerning White House intelligence briefing related to various foreign countries | |
| 3 | January 20, 2021 – August 8, 2022 |
| TOP SECRET//SI//NOFORN//FISA | |
| Undated document concerning military capabilities of a foreign country and the United States, with handwritten annotation in black marker |
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