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.

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:

 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, 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 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, 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.

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 record of Donald J.

Trump, and kept and maintained by the Trump Organization.

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:

 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 ________