READ: Unsealed 13-page statement of fact against Trump

READ: Full, unsealed indictment and statement of fact that describe how Trump ‘falsified business records’

  • The 34 charges relate to alleged falsifications of business records by Trump 
  • The statement of facts lays out Alvin Bragg’s case against him 

The unsealed 13-page statement of facts that accompanies the indictment against Donald Trump describes how Trump allegedly falsified business records to cover up three unsavory stories in the run-up to the 2016 presidential election. 

Trump has been charged with 34, felony E counts of falsifying business records for The Trump Organization. 

They all relate to how he allegedly tried to cover up payments to Cohen and American Media Inc. – AMI – after engaging in a ‘catch and kill’ scheme with them.  

According to the statement of facts that was unsealed today, Trump falsely listed payments to Michael Cohen, his attorney at time, as being for ‘legal services’, and also gave false descriptions of other payments in Trump Organization ledgers. 

The payments were to cover up three scandals – a hush money payment to Stormy Daniels, another of $150,000 to a second woman who said she’d slept with him, and a third of $30,000 to a Trump Tower doorman who said Trump had a love child.  

Trump today pleaded not guilty to all 34 counts. He will return to court in December. 

Neither the indictment nor the statement of facts describes precisely how Trump allegedly falsified documents himself. Bragg makes repeated reference to ‘the evidence’, but does not lay out exactly what that evidence is. 


In June 2015, Trump made a deal with AMI and its boss, David Pecker. 

The statement of facts describes how they met at Trump Tower to discuss Trump’s election chances, and how they could help. 

Donald Trump and David Pecker in 2004. According to Bragg’s indictment, it all began with their ‘catch and kill scheme’ to squash negative stories and get Trump into the Oval Office 

‘At the meeting, the AMI CEO agreed to help with the Defendant’s campaign, saying that he would act as the “eyes and ears” for the campaign by looking out for negative stories about the Defendant and alerting Lawyer A before the stories were published.

‘The AMI CEO also agreed to publish negative stories about the Defendant’s competitors for the election,’ according to the paperwork released today. 


The first scandal that Trump wanted to cover up was in October 2015 when Dino Sajudin, a doorman at Trump Tower, tried to sell a story to the press

The first scandal that Trump wanted to cover up was in October 2015 when Dino Sajudin, a doorman at Trump Tower, tried to sell a story to the press. 

He claimed Trump had a child out of wedlock, and that he could prove it through his access to the family. 

The story has been reported in the past by  

AMI paid him $30,000 for the exclusive rights to the story, preventing him from taking it to other outlets. 

According to the statement of facts, AMI knew the story wasn’t true, but held Sajudin in the agreement until after the election. 

The document does not specify if Trump ever reimbursed AMI for suppressing the doorman’s story. 

Instead, it says he invited the AMI CEO to his inauguration. 


In June 2016, a woman believed to be Karen McDougal, a former Playboy bunny, came forward with claims that she and Trump had had an affair.

According to Bragg’s office, Trump, Cohen and the Editor in Chief of AMI then had multiple conversations about who would ‘pay her off’. 

AMI paid her $150,000 allegedly to stop her from going anywhere else with the claims, but also for two covers and a series of articles. 

In June 2016, a woman believed to be Karen McDougal, a former Playboy bunny, came forward with claims that she and Trump had had an affair

AMI ‘falsely’ characterized this payment, according to the statement of facts.

Cohen told Trump he would open a shell company to transfer the money, according to the documents, which say their call was recorded.

‘So what do we got to pay for this? 150?’ Trump asked, then suggesting that it be paid in cash, according to the paperwork. 

Cohen disagreed and said it should be paid via check. 

Weeks later, Cohen set up a shell company called Resolution Consultants, LLC, which was then used to pay. 

Cohen agreed to buy the rights to the story from AMI for $125,000, according to the paperwork, but AMI later reneged. 

self’ and directed them to do it for him, Bragg claims. 


In October 2016, just a few weeks before the election and after Trump was shamed by the ‘grab ’em by the p***y’ Access Hollywood tape, Cohen and AMI heard that a second woman – Stormy Daniels – was preparing to come forward with her own story. 

Trump and Stormy Daniels at the golf tournament where they met and where she claims they slept together 

Cohen brokered a deal for $130,000 for Daniels’ silence, this time handling her attorney directly, and leaving AMI out of it. 

AMI had helped him initially by introducing him to Stormy’s representatives, according to the papers  


The deal was made, but rather than reimbursing them for the $130,000 payment, Trump and Cohen – along with Trump Organization CFO Allen Weisselberg – agreed that Trump would repay $420,000 total to them, according to the documents.

They agreed that over the next 12 months, Cohen would receive the payments in monthly installments of $35,000, Bragg claims. 

Trump Organization chief financial officer Allen Weisselberg looks on as then-U.S. Republican presidential candidate Donald Trump speaks during a news conference at Trump Tower

‘[Cohen] was to send an invoice to [Trump] through Trump Organization employees, falsely requesting payment of $35,000 for legal services rendered in a given month of 2017 pursuant to a retainer agreement. 

‘At no point did [Cohen] have a retainer agreement with Trump or the Trump Organization,’ the statement of facts read. 

The charges all relate to how these payments were categorized by Trump. 

Bragg says he falsely labeled them as retainers for legal services, which he believes signals a Class E Felony.   

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