by Norman L. Eisen, Ryan Goodman, Siven Watt and Francois Barrilleaux
November 1, 2024
This repository contains a collection of information for researchers, journalists, educators, scholars, and the public at large. This particular repository is part of a much larger collection – the Trump Trials Clearinghouse – which contains similar documents and information related to other criminal and civil trials involving former President Donald Trump.
The repository and other parts of the Trump Trials Clearinghouse will be continually updated. If you think the repository is missing something, please send recommendations for additional content by email to lte@justsecurity.org.
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Relevant State Court Proceedings
State of New York v. Trump, Case No.: IND-71543-23
Charging Documents and Arraignment
- State of New York response to Trump request for a bill of particulars (May 16, 2023)
- Trump request for bill of particulars (April 27, 2023)
- Trump case file (April 4, 2023)
- Transcript of arraignment (April 4, 2023)
- Trump Indictment (indicted on March 30, 2023 released on April 4, 2023) and statement of facts (April 4, 2023)
- Order unsealing indictment (April 4, 2023)
- Transcript of hearing on application of news organizations to unseal indictment (April 4, 2023)
- Application of news organizations to unseal indictment (March 31, 2023)
- Order on application of news organizations to permit videography, photography, and radio coverage of the arraignment (April 3, 2023)
- Supplemental submission in further support of application of news organizations to permit videography, photography, and radio coverage of the arraignment (April 3, 2023)
- State of New York response to application of news organizations to permit videography, photography, and radio coverage of the arraignment (April 3, 2023)
- Trump opposition to application of news organizations to permit videography, photography, and radio coverage of the arraignment (April 3, 2023)
- Application of news organizations to permit videography, photography, and radio coverage of the arraignment (March 31, 2023)
- Order confirming the existence of grand jury true bill and indictment (March 30, 2023) (entered March 31)
Verdict
- Verdict Form (May 30, 2024)
Sentencing
- Order adjourning (1) sentencing until November 26, 2024, and (2) decision on Trump motion to dismiss based on Presidential Immunity until November 12, 2024 (Sept. 6, 2024)
- State of New York letter to Court of Appeals, Second Circuit, confirming a September 6, 2024, decision by Justice Merchan on motion to adjourn sentencing until after the election (Sept. 5, 2024) [state filing in 2d Cir. removal appeal]
- Justice Merchan email confirming a decision will be rendered by September 5, 2024, on Trump pre-motion letter seeking adjournment of sentencing until after the election (Aug. 16, 2024) [exhibit to state filing in 2d Cir. removal appeal]
- State of New York letter in response to Trump request for adjournment of sentencing (Aug. 16, 2024) [entered Aug. 19]
- Trump pre-motion letter seeking adjournment of sentencing until after the election (Aug. 14, 2024)
- Order adjourning sentencing until September 18, 2024 (July 2, 2024)
Presidential Immunity
Vacate Jury Verdict and Dismiss Indictment
- Order adjourning (1) sentencing until November 26, 2024, and (2) decision on Trump motion to dismiss based on Presidential Immunity until November 12, 2024 (Sept. 6, 2024)
- Justice Merchan letter to parties on change of schedule: decision on motion to set aside jury verdict and dismiss the indictment on the basis of the U.S. Supreme Court’s presidential immunity decision in Trump v. United States to be handed down on September 16. 2024 (previously Sept. 6); and decision on Trump second renewed motion for recusal to be handed down the week of August 11, 2024 (Aug. 5, 2024)
- Trump reply in further support of his post-trial motion to vacate his conviction and dismiss the indictment on the basis of the U.S. Supreme Court's presidential immunity decision in Trump v. United States (July 31, 2024)
- State of New York memorandum of law in opposition to Trump post-trial motion to vacate his conviction and dismiss the indictment on the basis of the U.S. Supreme Court's presidential immunity decision in Trump v. United States (July 24, 2024) [entered July 25]
- Trump post-trial motion to vacate his conviction and dismiss the indictment on the basis of the U.S. Supreme Court's presidential immunity decision in Trump v. United States (and affirmation of Todd Clanche and exhibits in support) (July 10, 2024)
- Order setting briefing schedule for Trump post-trial motion to vacate his conviction and dismiss the indictment on the basis of the U.S. Supreme Court's presidential immunity decision in Trump v. United States, and adjourning sentencing until September 18, 2024 (July 2, 2024)
- State of New York response to Trump pre-motion letter seeking leave to file post-trial motion to vacate his conviction and dismiss the indictment on the basis of the U.S. Supreme Court's presidential immunity decision in Trump v. United States, and agreeing to adjourn sentencing pending resolution of the aforementioned (July 2, 2024)
- Trump pre-motion letter seeking leave to file post-trial motion to vacate his conviction and dismiss the indictment on the basis of the U.S. Supreme Court's presidential immunity decision in Trump v. United States file (July 1, 2024)
Exclude Evidence/Adjournment
- Trump pre-motion letter regarding evidentiary objection to State of New York offering evidence of Trump official acts during trial (April 15, 2024)
- Order denying as untimely Trump motion to exclude evidence and for an adjournment based on presidential immunity (April 3, 2024)
- State of New York opposition to Trump motion to exclude evidence and for an adjournment based on presidential immunity (March 13, 2024) [entered March 15]
- Order on the filing of future motions and directing State of New York to file response by March 13 to Trump motions to exclude evidence and for an adjournment based on presidential Immunity (March 8, 2024)
- Trump motions to exclude evidence and for an adjournment based on presidential immunity (March 7, 2024)
Removal
- State of New York letter to Justice Merchan advising of district court decision denying Trump motion for leave to file a second removal notice (Sept. 3, 2024) [entered Sept. 4]
- State of New York letter to Justice Merchan responding to Trump letter advising court of second removal notice, and requesting stay of proceedings (Aug. 30, 2024) [entered Sept. 3]
- Trump letter to Justice Merchan advising of his second removal notice, and requesting stay of proceedings (Aug. 29, 2024) [entered Aug. 30]
Recusal
Second Renewed Recusal Motion
- Decision denying Trump second renewed motion for recusal (Aug. 13, 2024)
- Justice Merchan letter to parties on change of schedule: decision on motion to set aside jury verdict and dismiss the indictment on the basis of the U.S. Supreme Court’s presidential immunity decision in Trump v. United States to be handed down on September 16. 2024 (previously Sept. 6); and decision on Trump second renewed motion for recusal to be handed down the week of August 11, 2024 (Aug. 5, 2024)
- State of New York letter not opposing Trump pre-motion letter to renew motion for recusal, but opposing the substantive motion and requesting for this letter to be treated as such opposition (Aug. 1, 2024) [entered Aug. 2]
- Trump pre-motion letter to renew motion for recusal (July 31, 2024)
Renewed Recusal Motion
- State of New York opposition to Trump renewed motion for recusal (April 5, 2024) [entered April 8]
- Trump renewed motion for recusal (April 3, 2024)
- State of New York opposition to Trump pre-motion letter for leave to file a renewed motion for recusal of Justice Merchan (April 2, 2024)
First Recusal Motion
- Order denying Trump motion for recusal of Justice Merchan (Aug. 11, 2023)
- State of New York response in opposition to Trump motion for recusal of Justice Merchan (and affirmation of Matthew Colangelo and exhibits) (June 14, 2023) [entered June 20]
- Trump memorandum of law in support of motion for recusal of Justice Merchan (and affirmation of Susan Necheles, Trump counsel, and two exhibits) (May 31, 2023)
Trial Material
Jury Instructions and Charges
- Final jury instructions and charges (May 29, 2024)
- Joint proposed jury instruction: falsifying business records in the first-degree (May 21, 2024) [entered May 22]
- Joint proposed jury instruction: NY Election Law § 17-152 (May 21, 2024) [entered May 22]
- Joint proposed jury instruction: Federal Election Campaign Act (May 21, 2024) [entered May 22]
- Joint proposed jury instruction: credibility of witnesses (May 21, 2024) [entered May 22]
- Joint proposed jury instruction: accomplice as a matter of law (May 21, 2024) [entered May 22]
- Joint proposed jury instruction: accessorial liability (May 21, 2024) [entered May 22]
- State of New York response to Trump requests to charge (May 17, 2024) [entered May 22]
- Trump requests to charge (May 14, 2024) [entered May 22]
- State of New York proposed jury instruction as to remaining counts (May 15, 2024) [entered May 22]
- State of New York proposed jury instructions (May, 13, 2024) [entered May 22]
Transcripts of Proceedings
- Day 23 Transcript: Second day of jury deliberations, and jury verdict (May 30, 2024)
- Day 22 Transcript: First day of jury deliberations (May 29, 2024)
- Day 21 Transcript: Summations (May 28, 2024)
- Day 20 Transcript: Robert Costello cross-examination, redirect, and recross–examination testimony; defense rests case; and charge conference (May 21, 2024)
- Day 19 Transcript: Michael Cohen cross-examination, redirect, and recross-examination testimony; defense first witness, Blanche Law’s Danny Sitko direct and cross-examination; and defense final witness, Robert Costello direct and cross-examination testimony (May 20, 2024)
- Day 18 Transcript: Michael Cohen cross-examination testimony (May 16, 2024)
- Day 17 Transcript: Michael Cohen direct and cross-examination testimony (May 14, 2024)
- Day 16 Transcript: Michael Cohen direct testimony (May 13, 2024)
- Day 15 Transcript: Trump White House personal assistant Madeleine Westerhout cross-examination, redirect, and recross-examination testament; AT&T’s Daniel Dixon direct and cross-examination testimony; Verizon’s Jennie Tomalin direct and cross-examination testimony; DANY’s Georgia Longstreet further direct and cross-examination testimony; and DANY’s Jaden Jarmel-Schneider direct, cross-examination, redirect, and recross-examination testimony (May 10, 2024)
- Day 14 Transcript: Stormy Daniels cross-examination, redirect, and recross-examination testimony; Trump Org.’s Rebecca Manochio direct and cross-examination testimony; Harper Collins’ Tracey Menzies direct and cross-examination testimony; and Trump White House personal assistant Madeleine Westerhout direct and cross-examination testimony (May 9, 2024)
- Day 13 Transcript: Stormy Daniels direct testimony (May 7, 2024)
- Day 12 Transcript: Trump Org. Jeffrey McConney direct, cross-examination, redirect, and recross-examination testimony; and Trump Org.’s Deborah Tarasoff direct and cross-examination testimony (May 6, 2024)
- Day 11 Transcript: DANY’s Douglas Daus cross-examination, redirect, and recross-examination testimony; DANY’s Georgia Longstreet direct and cross-examination testimony; and Hope Hicks direct and cross-examination testimony (May 3, 2024)
- Day 10 Transcript: Stormy Daniel counsel Keith Davidson direct, cross-examination, redirect, and recross-examination testimony; and DANY’s Douglas Daus direct and cross-examination testimony (May 2, 2024)
- Day 9 Transcript: First Republic Bank’s Gary Farro direct, cross-examination, redirect, and recross-examination testimony; C-SPAN’s Robert Browning direct testimony; Esquire Deposition Solutions’ Phillip Thompson direct testimony: and Stormey Daniels counsel Keith Davidson direct testimony (April 30, 2024)
- Day 8 Transcript: National Enquirer’s David Pecker cross-examination, redirect, and recross-examination testimony; Trump Org.’s Rhona Graff direct and cross-examination testimony; and First Republic Bank’s Gary Farro direct testimony (April 26, 2024)
- Day 7 Transcript: National Enquirer’s David Pecker direct and cross-examination testimony (April 25, 2024)
- Day 6 Transcript: Gag order violation hearing; and National Enquirer’s David Pecker direct testimony (April 23, 2024)
- Day 5 Transcript: Court opening; jury instructions; opening statements; Sandoval ruling; and David Pecker direct testimony (April 22, 2024)
- Day 4 Transcript: Jury selection (April 19, 2024)
- Day 3 Transcript: Jury selection (April 18, 2024)
- Day 2 Transcript: Jury selection (April 16, 2024)
- Day 1 Transcript: Jury selection (April 15, 2024)
Sandoval Evidence
- Trump letter regarding State of New York Sandoval notice (March 19, 2024)
- State of New York Sandoval notice (March 10, 2024) [entered April 17]
- Attachments to State of New York Sandoval notice (March 10, 2024)
Media Access Notices
- Update media access notice and media list for trial (April 24, 2024)
- Media access notice for jury selection through trial
Other
- Trump letter regarding alleged double-hearsay of certain AMI business records offered by State of New York (April 23, 2024) [entered April 25]
Restricting Extrajudicial Statements (Gag Order) and Findings of Contempt
Gag Order (including appeals)
- Order of the New York Court of Appeals dismising Trump appeal of Justice Merchan gag order (Sept. 12, 2024)
- Order of the Appellate Devision, First Department, rejecting Trump appeal challenging Justice Merchan June 25 order regarding terminating the gag order (Aug. 1, 2024)
- Order granting in part Trump motion to terminate the gag order (June 25, 2024)
- State of New York memorandum of law in opposition to Trump motion to terminate the gag order (and affirmations in support) (June 20, 2024) [entered June 21]
- Trump motion to terminate the gag order (and affirmation in support) (June 10, 2024) [entered June 11]
- State of New York response to Trump pre-motion letter requesting ht termination of the gag order (June 4, 2024) [entered June 5]
- Trump pre-motion letter requesting the termination of the gag order (June 3, 2024) [entered June 4]
- Order granting State of New York motion to clarify and amending March 26 gag order to include the family members of Justice Merchan and DA Bragg (April 1, 2024)
- Trump opposition to State of New York motion to clarify March 26 order limiting Trump extrajudicial statements (April 1, 2024)
- State of New York supplemental filing regarding clarifying the March 26 order limiting Trump extrajudicial statements (April 1, 2024)
- Trump opposition to State of New York pre-motion letter to clarify gag order (March 29, 2024)
- State of New York pre-motion letter to clarify March 26 gag order (March 28, 2024) [entered March 29]
- Order granting State of New York motion to restrict Trump from making or directing others to make public statements about witnesses, DA counsel and staff (except DA Bragg), court staff, the families of any counsel or staff, and (prospective) jurors (March 26, 2024)
- Trump opposition to State of New York motion for an order restricting his extrajudicial statements (March 4 2024)
- State of New York motion for an order restricting Trump extrajudicial statements (Feb. 22, 2024) [entered Feb. 26]
Contempt
- Third order requiring Trump to show cause as to why he should not be held in contempt and sanctioned for violating the gag order (April 25, 2024)
- Second order requiring Trump to show cause as to why he should not be held in contempt and sanctioned for violating the gag order (April 18, 2024)
- Order requiring Trump to show cause as to why he should not be held in contempt and sanctioned for violating the gag order (April 15, 2024)
- State of New York memorandum of law in support of its motion for Trump to be held in contempt and sanctioned for violating the court gag order (April 15, 2024) [entered April 16]
- Affirmation of Christopher Conroy in support of State of New York motion for contempt and sanctions (April 15, 2024) [entered April 16]
Venue Change (1st Dept., 2024-02365)
- First Department order denying Trump motion for a stay of trial pending the determination of his motion for a change of venue (April 8, 2024)
Justice Merchan Jurisdiction and Authority, including Immunity, Recusal and Motions Procedure (Article 78) (1st Dept., 2024-02413)
Witness Evidence
- Trump pre-motion letter in response to the court request for limiting instruction relating to (1) anticipated testimony from Michael Cohen regarding his 2018 guilty plea to a FECA violation, and (2) any testimony from David Pecker concerning AMI Sept. 2018 non-prosecution agreement, 2021 conciliation agreement with the FEC, and/or the FEC 2021 “Factual and Legal Analysis” regarding AMI (entered April 17, 2024) [entered April 18]
Subpoenas
- Order on State of New York motion to quash Trump subpoena of Mark Pomerantz subpoena and for a protective order (May 10, 2024)
- Trump opposition to State of New York motion to quash his subpoena of Mark Pomerantz, with affirmation and memorandum of law in support (April 5, 2024) [entered April 8]
- State of New York motion to quash Trump subpoena of Mark Pomerantz subpoena and for a protective order, with affirmation and memorandum of law in support (and exhibits) (April 3, 2024)
- Order denying Trump motion to compel compliance with a subpoena served on Stormy Daniels (April 23, 2024)
- Trump memorandum of law in support of motion to compel compliance with a subpoena served on Stormy Daniels (April 12, 2024)
- State of New York response to Trump pre-motion letter for leave to file motion to enforce Requests 1 and 2 of a subpoena served on Stormy Daniels and to compel the production of responsive documents (April 8, 2024)
- Trump pre-motion letter for leave to file motion to enforce Request 1 and 2 of a subpoena served on Stormy Daniels and to compel the production of responsive documents (April 5, 2024) [entered April 8]
- Order granting motion to quash Trump subpoena to NBC re Stormy Daniels documentary (April 5, 2024)
- NBC reply to Trump opposition to its motion to quash Trump subpoena of records pertaining to the Stormy Daniels documentary (April 1, 2024) [entered April 4]
- NBC motion to quash Trump subpoena of records pertaining to the Stormy Daniels documentary (March 20, 2024) [entered March 25]
- Trump opposition to State of New York motion to quash his subpoena of Mark Pomerantz, with affirmation and memorandum of law in support (April 5, 2024) [entered April 8]
- State of New York opposition to Trump motion to reargue his opposition to the state motion to quash Trump subpoena of Michael Cohen (Jan. 24, 2024) [entered Jan. 25]
- Trump opposition to State of New York motion to quash his subpoena of Michael Cohen (Nov. 30, 2023)
- State of New York (1) notice of motion to quash Trump subpoena of Michael Cohen documents and communications and for a protective order, (2) affirmation and memorandum of law in support of motion, (3) exhibits (Nov. 9, 2023) [entered Nov. 14]
Discovery Dispute and March 25 Hearing
- Order denying Trump motion for discovery sanctions (May 23, 2024)
- State of New York memorandum of law in opposition to Trump motion to dismiss and for an adjournment based on discovery violations regarding discovery (March 18, 2024) [entered March 21]
- Mark Pomerantz affirmation in support of State of New York opposition to Trump motion to dismiss and for an adjournment based on discovery violations (March 18, 2024) [entered March 21]
- Christopher Conroy affirmation in support of State of New York opposition to Trump motion to dismiss and for an adjournment based on discovery violations (March 18, 2024) [entered March 21]
- Matthew Colangelo affirmation in support of State of New York opposition to Trump motion to dismiss and for an adjournment based on discovery violations (March 18, 2024) [entered March 21]
- Susan Hoffinger affirmation in support of State of New York opposition to Trump motion to dismiss and for adjournment based on discovery violations (March 18, 2024) [entered March 21]
- State of New York memorandum of law in opposition to Trump motion regarding discovery of USAO-SDNY documents (March 18, 2024) [corrected March 20; entered March 21]
- Christopher Conroy affirmation in support of State of New York opposition to Trump motion regarding discovery of USAO-SDNY documents (March 18, 2024) [entered March 21]
- Trump counsel letter responding State of New York supplemental notice regarding the production of records from the U.S. Attorney's Office (March 15, 2024)
- State of New York supplemental notice regarding the production of records from the U.S. Attorney's Office (March 15, 2024)
- Trump counsel letter responding to State of New York notice regarding the production of records from the U.S. Attorney's Office and consent to an adjournment not exceeding 30 days (March 14, 2024)
- State of New York notice regarding the production of records from the U.S. Attorney's Office and consent to an adjournment not exceeding 30 days (March 14, 2024)
- Trump motion to dismiss, or in the alternative preclude witness testimony, and for an adjournment of at least 90 days based on discovery violations (March 8, 2024)
- Affirmation of Todd Blanche and exhibits in support of Trump motion to dismiss, or in the alternative preclusion of witness testimony, and for an adjournment of at least 90 days based on discovery violations (March 8, 2024)
- Trump letter seeking permission to file motion to dismiss, or in the alternative preclusion of witness testimony, and for an adjournment of at least 90 days based on discovery violations (March 8, 2024)
Restricting the Inspection of Discovery
- Order granting State of New York motion for a protection order limiting Trump inspection and use of certain discovery material and information (April 24, 2023)
Voir Dire (July Selection)
- Trump letter regarding court April 8 letter on jury selection and questionnaires (April 11, 2024) [entered April 12]
- Press request to be present during voir dire and for public a transcript of voir dire proceedings (April 12, 2024)
- Court letter on (1) excusing jurors who self-identify as unable to serve, (2) instructions regarding the use of an anonymous jury, and (3) the jury questionnaire and the permissible scope of voir dire (April 8, 2024)
Pretrial Publicity
- Order denying Trump motion for further adjournment based on prejudicial pretrial publicity (April 12, 2024)
- State of New York motion in opposition to Trump motion for further adjournment based of prejudicial pretrial publicity (April 1, 2024) [entered April 3]
- Trump motion for further adjournment based of prejudicial pretrial publicity (March 18, 2024)
- Affirmation of Todd Blanche in support of Trump motion for further adjournment based of prejudicial pretrial publicity (March 18, 2024)
- Trump notice regarding motion for further adjournment based of prejudicial pretrial publicity (March 18, 2024)
- Supplemental premotion letter regarding Trump motion for leave to file motion for further adjournment based of prejudicial pretrial publicity (March 18, 2024)
- Pre-motion letter seeking leave to file a motion for further adjournment based on prejudicial pretrial publicity (March 10, 2024)
Unsealing Docket and Public Access to Filings
- Order on Trump motion for access to public filings (May 16, 2024)
- Order on Trump motion for public proceedings (March 26, 2024)
- Letter from news organizations regarding Trump motion for public proceedings (March 22, 2024)
- State of New York response to Trump motion for public proceedings (March 12, 2024) [entered March 19]
- Trump pre-motion letter seeking leave to file a motion for (1) unsealing and public access to all pleadings, orders, and written communications that have involved the court and its parties, including communications sent by letter and substantive email, and (2) simultaneous public access of all future pleadings, orders, and written communications except to the extent redactions are required by the protective order or law (March 10, 2024)
Filing of Future Motions
- Order denying Trump motion to vacate March 8 order on the filing of future motions (March 26, 2024)
- State of New York response opposing Trump leave to file motion to vacate Court March 8 order on filing future motions (March 12 2024) [entered March 19]
- Trump counsel pre-motion letter seeking leave to file a motion to vacate March 8 order on the filing of future motions (March 10, 2024)
- Order on the filing of future motions (March 8, 2024)
Advice-of-Counsel
- Order on State of New York motions in limine, including granting motion to exclude Trump “presence of counsel” defense (March 18, 2024)
- Trump notice concerning his intent to rely on an advice-of-counsel defense (March 11, 2024)
Motions in Limine
- Trump pre-motion letter seeking reargument of the court April 15, 2024, clarification of the March 18, 2024 in limine ruling relating to the so-called “Access Hollywood tape” (April 17, 2024) [entered April 18])
- Order on Trump motion in limine (March 18, 2024)
- State of New York opposition to Trump motions in limine (Feb. 29, 2024) (entered March 5)
- Trump motions in limine (and notice of motions) (Feb. 22, 2024) [entered Feb. 26]
- Order on State of New York motions in limine (March 18, 2024)
- Trump opposition to State of New York motion in limine (Feb. 29, 2024)
- State of New York motions in limine (Feb. 22, 2024) [entered Feb. 26]
Omnibus Motions to Dismiss
- Order denying all motions in omnibus motions to dismiss, except for granting motion to inspect grand jury minutes and precluding the State of New York from introducing any new or different “other crime” theories (Feb. 13, 2024) [entered Feb. 15]
- State of New York sur-reply in opposition to Trump omnibus motions (Nov. 27, 2023) [entered Nov. 29]
- Trump reply memorandum of law in support of his omnibus motions to dismiss (Nov. 21, 2023)
- State of New York memorandum of law in opposition to Trump omnibus motions (Nov. 9, 2023) [entered Nov. 15]
- Affirmation of Christopher Conroy in support of State of New York opposition to Trump omnibus motions to dismiss (Nov. 9, 2023) [entered Nov. 15]
- Exhibits to State of New York memorandum of law in opposition to Trump omnibus motions (Nov. 9, 2023) [entered Nov. 15]
- Notice of Trump motion to file, with limited redactions, public copy of papers in support of omnibus motions to dismiss (including exhibits and affirmation of Todd Blanche in support) (Oct. 5, 2023) [entered Oct. 11]
Protecting Juror Information
- Decision and order on State of New York motion for protective order regulating the disclosure of juror information (March 7, 2024)
- Trump opposition to State of New York motion for a protective order regulating disclosure of juror addresses and names (March 4, 2024)
- State of New York motion for a protective order regulating disclosure of juror addresses and names (Feb. 22, 2024) [entered Feb. 26]
Scheduling
Discovery
- State of New York (1) notice of motion to compel Trump to provide reciprocal discovery, (2) affirmation and memorandum of law in support, (3) exhibits (Nov. 9, 2023) [entered Nov. 14]
Joseph Tacopina Conflict
- Order for Tacopina conflict hearing (April 28, 2024)
- State of New York letter to Judge Merchan regarding Tacopina conflict of interest raised by Stormy Daniels counsel (April 14)
- Joseph Tacopina letter to Judge Merchan in response to counsel of Stormy Daniels conflict of interest letter (April 12, 2023)
- Counsel of Stormy Daniels letter to Joseph Tacopina regarding alleged conflict of interest (April 3, 2023)
Other
- State of New York opposition to Trump motions for reconsideration and ancillary relief of (1) an in-person status conference to discuss adjourning the trial date, and (2) disclosure of communications between the court and Judge Chutkan (Nov, 2, 2023) [entered Nov. 3]
- Judge Merchan response denying news organizations request for an explanation by State of New York for the basis for sealing some of its applications (April 13, 2024)
- Letter of news organizations to Judge Merchan requesting an explanation by State of New York for the basis for sealing some of its applications (April 13, 2024)
Relevant Federal Court Proceedings
Federal removal proceedings
Second Removal Notice
Court of Appeals, Second Circuit, Case No: 24-2299
- Trump opening brief in his appeal from Hellerstein, J. order denying leave to file second notice of removal (Oct. 14, 2024)
- Order granting Trump request to file on or before Oct. 14, 2024, an opening brief in his appeal from Hellerstein, J. order denying leave to file second notice of removal (Sept. 16, 2024)
- Order denying Trump motion for an emergency administrative stay pending full briefing his motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal (Sept. 12, 2024)
- State of New York opposition to Trump motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal (Sept. 9, 2024)
- Trump supplemental authority letter in support of motion to stay and for an emergency administrative stay, regarding Hellerstein, J. order denying motion to stay pending appeal and Justice Merchan adjournment of presidential immunity decision and sentencing (Sept. 9, 2024)
- Trump reply in support of motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal, and for an emergency administrative stay pending full briefing of the stay motion (Sept. 5, 2024)
- State of New York opposition to the emergency administrative stay request in Trump motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal (to later file a response to the stay motion) (Sept. 5, 2024)
- Trump motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal, and for an emergency administrative stay pending full briefing of the stay motion (Sept. 4, 2024)
- Order granting America First Policy Institute motion for leave to file an amicus curiae brief in support of Trump motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal (Sept. 11, 2024)
- Amicus curiae brief of America First Policy Institute in support of Trump motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal (Sept. 10, 2024) [entered Sept. 11]
- America First Policy Institute motion for leave to file an amicus curiae brief in support of Trump motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal (Sept. 10, 2024)
- Order setting oral argument for September 10, 2024, on Trump motion for a stay pending appeal from Hellerstein, J. order denying leave to file second notice of removal (Sept. 6, 2024)
- State of New York letter confirming a September 6, 2024, decision by Justice Merchan on motion to adjourn sentencing until after the election (Sept. 5, 2024)
- Second Circuit docketing notice of Trump appeal of District Court order denying leave to file second removal notice (Sept. 4, 2024)
District Court of the Southern District of New York (Hellerstein,J.), Case No.: 1:23-cv-03773
- Order and opinion denying as academic Trump motion to stay Hellerstein J. order denying motion for leave to file a second notice of removal (Sept. 6, 2024)
- Memorandum of law in support of Trump motion for stay pending appeal to the Court of Appeals, Second Circuit, from Hellerstein, J. opinion and order denying Trump motion for leave to file a second notice of removal (Sept. 4, 2024)
- Trump motion for stay pending appeal to the Court of Appeals, Second Circuit, from Hellerstein, J. opinion and order denying Trump motion for leave to file a second notice of removal (Sept. 4, 2024)
- Trump notice of appealing to the Court of Appeals, Second Circuit, from Hellerstein, J. order and opinion denying Trump motion for leave to file second notice of removal (Sept. 3, 2024)
- Order and opinion denying Trump motion for leave to file a second notice of removal (Sept. 3, 2024)
- Memorandum of law in support of Trump motion for leave to file a second notice of removal (Sept. 3, 2024)
- Trump motion for leave to file second notice of removal (Sept. 3, 2024)
- Court notice of deficient pleading regarding notice of removal (Aug 30, 2024)
- Trump second notice of removal (Aug. 29, 2024)
First Removal Notice, District Court of the Southern District of New York (Hellerstein, J.), Case No.: 1:23-cv-03773
- Order granting Trump notice of motion to dismiss 2nd Circuit appeal of district court order denying his removal petition in New York (Nov. 15, 2023)
- Trump notice of appeal to 2nd Circuit Court of Appeals (July 28, 2023)
- Order and opinion denying Trump motion to remove and granting State of New York motion to remand (July 19, 2023)
- Order regulating removal evidentiary hearing (June 23, 2023)
- State of New York memorandum of law in support of its reply in support of its motion to remand (June 23, 2023)
- Joint letter in agreement on procedures and evidence at removal evidentiary hearing (June 22, 2023)
- Trump memorandum of law in support of his opposition to State of New York motion to remand (June 15, 2023)
- Order granting motion to seal exhibits (June 6, 2023)
- State of New York motion to seal seven exhibits of its motions to remand (and memorandum of law in support; declaration of Matthew Colangelo) (May 30, 2023)
- State of New York notice of motion to remand (and memorandum of law in support) (May 30, 2023)
- Order on scheduling for Trump removal proceedings (May 9, 2023)
Trump notice of removal (May 4, 2023)
DA Alvin Bragg v. Rep. Jim Jordan
Case No.: 1:23-cv-03032 (civil proceedings)
- Background: Mark Pomerantz opening statement in congressional deposition (May 12, 2023)
- Notice of Dismissal Following Settlement (April 24, 2023)
- Opinion and Order Denying Temporary Restraining Order (April 19, 2023)
- Amicus Brief Supporting Alvin Bragg Motion for Interim Injunctive Relief (April 17, 2023)
- Mark Pomerantz Declaration Supporting Alvin Bragg Complaint (April 17, 2023)
- Mark Pomerantz Response Supporting Alvin Bragg Complaint (April 17, 2023)
- Congressional Opposition Brief to Alvin Bragg Complaint (April 17, 2023)
- Order Denying Temporary Restraining Order (April 11, 2023)
- Memorandum of Law Supporting Alvin Bragg Request for a Temporary Restraining Order (April 11, 2023)
- Manhattan DA Alvin Bragg Complaint against Jim Jordan (April 11, 2023)
- Chairman Jim Jordan, Letter to Matthew Colangelo (April 7, 2023)
- Chairman Jim Jordan, Subpoena to Mark Pomerantz (April 6, 2023)
- Manhattan DA Bragg, Response to Second Letter from House Committee Chairs (March 31, 2023)
- Mark Pomerantz, Response to Chairman Jim Jordan (March 27, 2023)
- Manhattan DA Bragg, Letter to Mark Pomerantz (March 25, 2023)
- House Committee Chairs, Second Letter to DA Alvin Bragg (March 25, 2023)
- DA Bragg, Response to First Letter from House Committee Chairs (March 23, 2023)
- Jim Jordan, Letter from Chairman to Mark Pomerantz (March 22, 2023)
- House Committee Chairs, First Letter to DA Alvin Bragg (March 20, 2023)
Federal Election Commission
- Donald Trump Complaint against Michael Cohen (April 12, 2023), Case No,: 1:23-cv-21377
- Federal Election Commission, Michael Cohen et al. FEC Case Dissent from Dismissal Commissioners’ Statement of Reasons (May 6, 2021)
- Federal Election Commission, Michael Cohen et al. FEC Case Dismissal Commissioners’ Statement of Reasons (April 26, 2021)
- Federal Election Commission, Karen McDougal, American Media Inc., Factual and Legal Analysis (April 13, 2021)
- American Media Inc. Non-Prosecution Agreement with Department of Justice (September 20, 2018)
- Common Cause FEC Complaint re: American Media Inc. (April 12, 2018)
- Karen McDougal, American Media Inc. Complaint in Superior Court of California (March 20, 2018)
- Common Cause FEC Complaint re: Michael Cohen et al. (March 12, 2018)
- Common Cause FEC Complaint re: Trump and John Doe (January 22, 2018)
Relevant Michael Cohen documents
- State of New York (1) notice of motion to quash Trump subpoena of Michael Cohen documents and communications and for a protective order, (2) affirmation and memorandum of law in support of motion, (3) exhibits (Nov. 9, 2023) [e-filed Nov. 14]
- Michael Cohen, Testimony to House of Representatives Committee on Oversight and Reform (February 27, 2019)
- Michael Cohen – Sentencing Hearing Transcript (December 12, 2018)
- Michael Cohen – Sentencing Memorandum – DOJ Submission (December 7, 2018)
- Michael Cohen – Sentencing Memorandum – Cohen Submission (November 30, 2018)
- Michael Cohen – Plea Hearing Transcript (November 29, 2018)
- Michael Cohen – Plea Agreement (August 21, 2018)
- Michael Cohen – Search Warrant (April 8, 2018)
Key Statutes
- Falsifying Business Records in the First Degree New York Penal Law § 175.10
- Campaign Receipts and Expenditures, Violations; Penalties New York Election Law § 14-126
- Background: Model New York jury instructions for falsifying business records (no date)
Just Security Writings
Public Resources and Expert Backgrounders
- Norman L. Eisen, Andrew Warren and Siven Watt, A Complete Guide to the Manhattan Trump Election Interference Prosecution, Just Security (March 27, 2024)
- Norman L. Eisen and Andrew Warren, A Guide to Thursday’s Hearing on Trump’s Motion to Dismiss the Manhattan Prosecution, Just Security (Feb. 14, 2024)
- Gretchen Knaut, Norman L. Eisen, McKenzie Carrier, Vicka Heidt, Greg Phea and Madison Gee, Detailed Chronology in Trump-Cohen Hush Money Investigation, Just Security (May 24, 2023)
- Ryan Goodman, Norman L. Eisen, Siven Watt, Joshua Kolb and Joshua Stanton, The Broad Scope of “Intent to Defraud” in the New York Crime of Falsifying Business Records, Just Security (April 3, 2023)
- Siven Watt and Norman L. Eisen, Survey of Past Criminal Prosecutions for Covert Payments to Benefit a Political Campaign, Just Security (March 30, 2023)
- Siven Watt, Norman L. Eisen and Ryan Goodman, Survey of Past New York Felony Prosecutions for Falsifying Business Records, Just Security (March 21, 2023)
Analysis
- Norman L. Eisen, Karen Agnifilo, Andrew Warren, Jacob Kovacs-Goodman and Siven Watt, Why Trump Will Likely be Held in Contempt and What Then, Just Security (April 25, 2024)
- Adam Klasfeld, ‘Election Fraud, Pure and Simple’: Trump’s Prosecutors Move Beyond Stormy Daniels in Wide-Lens Trial Opening, Just Security (April 22, 2024)
- Norman L. Eisen, Adam Klasfeld and Jacob Kovacs-Goodman, 41 Star Witnesses and Bit Players in Trump’s NY Criminal Trial, Just Security (April 17, 2024)
- Adam Klasfeld, Trump’s Forbidden Legal Strategy: What New York Law Won’t Let the Jury Do by Adam Klasfeld, Just Security (April 15, 2024)
- Adam Klasfeld, Dispatches from the Trump Trial Courtroom in New York, Just Security (April 14, 2024)
- Adam Klasfeld, Manhattan DA Requests ‘Narrowly Tailored’ Gag Order on Trump Before March Trial, Just Security (Feb. 26, 2024)
- Adam Klasfeld, Trump Fails to Get N.Y. Hush-Money Case Dismissed, as Judge Gears Up for March Trial, Just Security (Feb. 15, 2024)
- Samuel Issacharoff, Prosecuting a President – Under What Conditions Is It Warranted?, Just Security (July 6, 2023)
- Paula Junghans, Norman L. Eisen, Siven Watt, Joshua Stanton and Fred Wertheimer, The Untold Strength of Tax Crimes in Manhattan DA’s Case Against Former President Trump, Just Security (May 24, 2023)
- Daniel Hemel, The Question of Tax Fraud in Manhattan DA’s Case Against Former President Trump, Just Security (May 23, 2023)
- Karen Friedman Agnifilo interview by Paras Shah, The Just Security Podcast: An Indictment of Donald Trump, Just Security (March 31, 2023)
- Joshua Stanton, Norman L. Eisen, E. Danya Perry and Fred Wertheimer, The Manhattan DA’s Charges and Trump’s Defenses: A Detailed Preview, Just Security (March 20, 2023)
- Ryan Goodman, Pomerantz vs. Pomerantz: An Annotation of His Leaked Resignation Letter in Manhattan DA Trump Investigation, Just Security (Feb. 7, 2023)
- Norman L. Eisen, E. Danya Perry and Fred Wertheimer, Trump’s Hush Money is News Again. Here’s Why We Should Care, Just Security (Feb. 7, 2023)
- Andrew Weissmann, The Curious Case of Alvin Bragg — Reconsidering the DA’s Trump investigation, Just Security (Aug. 25, 2022)
Media and Other Resources
- Norman Eisen, Andrew Weissmann and Joshua Kolb, Alvin Bragg keeps winning — and nobody’s talking about it, MSNBC (Sept. 13, 2023)
- Nadine El-Bawab and Aaron Katersky, Timeline: Manhattan DA's Stormy Daniels Hush Money Case against Donald Trump, ABC News (Aug. 28, 2023)
- Ben Protess, Kate Christobek, Jonah E. Bromwich, William K. Rashbaum and Sean Piccoli, In Trump Case, Bragg Pursues a Common Charge With a Rarely Used Strategy, The New York Times (May 7, 2023)
- Quinta Jurecic, This Is Actually Quite Bad, The Atlantic (April 5, 2023)
- Jed Handelsman Shugerman, The Trump Indictment Is a Legal Embarrassment, The New York Times (April 5, 2023)
- Kyle Cheney, Erica Orden and Josh Gerstein, Bragg’s case against Trump hits a wall of skepticism — even from Trump’s critics, POLITICO (April 5, 2023)
- NYS Unified Court System Office of Court Administration (April 4, 2023)
- Karen Friedman Agnifilo and Norman Eisen, We Finally Know the Case Against Trump, and It Is Strong, The New York Times (April 4, 2023)
- Jonah E. Bromwich, Here are the Key Events that Led to the Indictment, The New York Times (March 30, 2023)
- David French, The Potential Trump Indictment Is Unwise, The New York Times (March 26, 2023)
- Ryan Goodman and Andrew Weissman, Make No Mistake, the Investigation of Donald Trump and the Stormy Daniels Scheme Is Serious, The New York Times (March 21, 2023)
- Andrew Weissman, An insider’s critical view of an investigation of Donald Trump, The Washington Post (Feb. 3, 2023)
Selected Trump Statements
- Donald Trump, Truth Social on Not Getting a Fair Trial for Hush Money Case, Truth Social (March 30, 2023)
- Donald Trump, Truth Social "Thugs and Radical Left Monsters...", Truth Social (March 30, 2023)
- Donald Trump, Truth Social Respect for Grand Jury, Truth Social (March 29, 2023)
- Donald Trump, Truth Social “Only a degenerate psychopath that truely (sic) hates the USA!”, Truth Social (March 24, 2023)