by Norman L. Eisen, Ryan Goodman, Siven Watt, Francois Barrilleaux, Sasha Matsuki and Arava Rose
November 29, 2023
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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Selected Court Proceedings
Summons and Complaint
- State of New York summons and complaint (Sept. 21, 2022)
Summary Judgment
NY First Department Appeal
- Defendants reply memorandum of law in support of stay pending appeal (Nov. 9, 2023)
- State of New York opposition to defendants motion for a stay of Justice Engoron Sept. 26 and Oct. 4 orders on summary judgment, and stay of trial, pending appeal (Oct. 30, 2023)
- First Department appellate court decision (1) refusing defendants application for interim stay of Justice Engoron Sept. 26 and Oct. 4 orders on summary judgment, and stay of trial, (2) granting interim stay on cancellation of business certificates, and (3) setting scheduling for motions hearing on defendants motion to stay pending appeal (Oct. 6, 2023)
- State of New York opposition to defendants emergency application to First Department appellate court for interim stay of Justice Engoron Sept. 26 and Oct. 4 orders on summary judgment, and stay of trial, pending appeal (Oct. 6, 2023)
- Defendants emergency application to First Department appellate court for interim stay of Justice Engoron Sept. 26 and Oct. 4 orders on summary judgment, and stay of trial, pending appeal (Oct. 6, 2023)
- Defendants notice of appeal and informational statement to First Department appellate court for interim stay of Justice Engoron Sept. 26 and Oct. 4 orders on summary judgment, and stay of trial, pending appeal (Oct. 4, 2024)
NY Supreme Court (trial court)
- Exhibit A transcript of trial (Nov. 15, 2023).
- Defendants affirmation of support defendants motion for a mistrial (Nov. 15, 2023).
- David Demarest expert affirmation (Nov. 15, 2023).
- Defendants’ memorandum of law in support of motion for a mistrial (Nov. 15, 2023).
- Defendants’ Proposed Order to show cause for mistrial (Nov. 15, 2023).
- Habba Madaio & Associates LLP notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions (Oct. 25, 2023)
- Michael Madaio notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions (Oct. 25, 2023)
- Armen Morian notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions (Oct. 24, 2023)
- Morian Law PLLC notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions (Oct. 24, 2023)
- Robert & Robert PLLC notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions against defendants counsel (Oct. 23, 2023)
- Clifford S. Robert notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions against defendants counsel (Oct. 23, 2023)
- Michael Farina notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions against defendants counsel (Oct. 23, 2023)
- Continental PLLC notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions against defendants counsel (Oct. 23, 2023)
- Christopher M. Kise notice of appeal of Sept. 26 order granting in part State of New York motion for sanctions against defendants counsel (Oct. 23, 2023)
- Defendants notice of appeal of supplemental order on summary judgment (Oct. 5, 2023)
- Defendants notice of appeal of order granting partial summary judgment (Oct. 4, 2023)
- Supplemental order to Sept. 26 order, directing (1) parties to provide information on potential receivers, and (2) defendants to provide (to the Independent Monitor) Section 130 Entities (Oct. 4, 2023) [e-filed Oct. 5, 2023]
- Order granting in part State of New York motions for partial summary judgment and sanctions against defendants counsel, and denying defendants motions for summary judgment (Sept. 26, 2023) [e-filed Sept. 27]
Gag Orders
NY First Department Appeal
- Defendants affirmation in further support of interim stay pending full review of joint Article 78 petition against Engoron gag orders and findings of contempt (Nov. 26, 2023) [e-filed Nov. 27]
- Affirmation on behalf of Justice Engoron in opposition to joint Article 78 petition against Justice Engoron gag orders and findings of contempt (Nov. 22, 2023)
- State of New York affirmation in opposition to joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Nov. 22, 2023)
- First Department appellate court order granting interim stay of Justice Engoron gag orders and imposition of sanctions pending full review of joint Article 78 petition (Nov. 16, 2023)
- State of New York letter to court in opposition to defendants application for an interim stay of Justice Engoron gag orders and imposition of sanctions pending full review of joint Article 78 petition (Nov. 16, 2023)
- Defendants application for an interim stay of Justice Engoron gag orders and imposition of sanctions pending full review of joint Article 78 petition (Nov. 16, 2023)
- Defendants notice of joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Nov. 15, 2023)
Trial Documents
- Gag order as to Trump counsel (Nov. 3, 2023)
- Proof of Trump satisfying fines for $5,000 and $10,000 (Oct. 26, 2023)
- Court order fining Trump $10,000 for violating gag order (Oct. 26, 2023)
- Court order fining Trump $5,000 for violating gag order (Oct. 20, 2023)
- Gag order as to Donald Trump (Oct. 3, 2023 entered on record; Oct. 26, 2023 so-ordered)
Motion for Mistrial
- Order denying defendants proposed order to show cause granting a mistrial (Nov. 17, 2023) [e-filed Nov. 20]
- State of New York letter to court regarding defendants proposed order to show cause granting a mistrial (Nov. 16, 2023)
- Affirmation of counsel Clifford Robert in support of proposed order to show cause granting a mistrial (Nov. 15, 2023)
- Defendants memorandum of law in support of motion for mistrial (Nov. 15, 2023)
- Defendants proposed order to show cause granting a mistrial (Nov. 15, 2023)
- Expert affirmation of David Demarest J.S.C. (Ret.) in support of proposed order to show cause granting a mistrial (Nov. 14, 2023) [e-filed Nov. 15]
Trial filings and Motions in Limine
- Order denying motion to quash subpoenas regarding non-party Ivanka Trump (Nov. 16, 2023) [e-filed Nov. 17]
- Order Denying Motion to Quash Subpoenas regarding Ivanka Trump (Nov. 16, 2023)
- Non-party Ivanka Trump letter to First Department withdrawing appeal of Oct. 30 order denying motion to quash subpoenas (Nov. 3, 2023)
- First Department order denying non-party Ivanka Trump application for interim stay of Oct. 30 order denying motion to quash subpoenas pending appeal (Nov. 2, 2023)
- Non-party Ivanka Trump notice of appeal to First Department of Oct. 30 order denying her motion to quash subpoenas (Nov. 1, 2023)
- Order denying non-party Ivanka Trump motion to quash subpoenas, on the record October 27, 2023 (Oct. 30, 2023)
- Defendants memorandum of law in support of non-party Ivanka Trump motion to quash subpoenas (Oct. 26, 2023)
- State of New York memorandum of law in opposition to non-party Ivanka Trump Oct. 19 motion to quash subpoenas (Oct. 25, 2023) [e-filed Oct. 26]
- Affirmation of State of New York attorney Sherief Gaber in opposition to non-party Ivanka Trump motion to quash subpoenas (Oct. 25, 2023) [e-filed Oct. 26]
- Non-party Ivanka Trump notice of motion for an order quashing subpoenas served on TTT Consulting LLC, Ivanka OPO LLC, and 502 Park Project, or, in the alternative, a protective order (Oct. 19, 2023)
- Non-party Ivanka Trump memorandum of law in support of motion to quash subpoenas and, in the alternative, a protective order (Oct. 19, 2023)
- State of New York notice of leave to make oral motion in limine to exclude evidence of four expert witnesses (Nov. 8, 2023)
- State of New York response to defendants memorandum of law in support of motion in limine to preclude expert testimony of Michiel McCarty (Oct. 31, 2023)
- Defendants submitted opening statement (Oct. 3, 2023).
- State of New York submitted opening statement presentation (Oct. 2, 2023)
- Defendants Witness List (as of Sept. 27, 2023) (Sept. 27, 2023)
- State of New York Witness List (as of Sept. 27, 2023) (Sept. 27, 2023)
- State of New York submitted facts to be proven at trial (Sept. 26, 2023)
- State of New York note of issue and certificate of readiness for trial (July 31, 2023)
Depositions
- Transcript of video deposition of Donald J. Trump (April 13, 2023)
- Transcript of video deposition of Frederick Chin (July 26, 2023)
- Transcript of video deposition of Robert Unell (July 21, 2023)
- Partial video deposition of Michael Cohen (April 28, 2023) [first played during Day 1 of trial, October 23, 2023]
- Michael Cohen counsel confirming his client's attendance at his April 28 2023, deposition (April 27, 2023)
- Order directing Michael Cohen to respond as to why he should not be compelled, granting defendants’ request for expedited briefing schedule (April 6, 2023)
- Counsel Alina Habba proposed order to show cause to compel deposition testimony of Michael Cohen (April 3, 2023)
Scheduling
- Amended scheduling order (Sept. 8, 2023)
Preliminary Conference Orders
- State of New York memorandum of law in opposition to defendants’ motion to vacate and modify the preliminary conference order (March 15, 2023)
- Preliminary conference order on scheduling and other matters (Nov. 22, 2022)
- Defendants’ proposed preliminary conference order on scheduling and other matters (Nov. 22, 2022)
- State of New York proposed preliminary conference order on scheduling and other matters (Nov. 22, 2022)
Confidentiality Orders
Preliminary Injunction
- State of New York and Ivanka Trump joint stipulation and proposed order to modify Nov. 4, 2022, preliminary injunction order to exclude Ivanka Trump as a defendant (Dec. 5, 2022) [submitted Dec. 1]
- Decision and order granting State of New York motion for a preliminary injunction order (Nov. 4, 2022)
Independent Monitor
- Independent Monitor Barbara Jones letter to Justice Engoron (April 11, 2023)
- Supplemental order on Independent Monitor’s duties, powers and fees (Nov. 17, 2022)
- Order appointing Hon. Barbara S. Jones (Ret.) as the Independent Monitor (Nov. 14, 2022)
- Letter to court by OAG on suggested Independent Monitors (Nov. 10, 2022)
- Letter to court by counsel Alina Habba on suggested Independent Monitors (Nov. 10, 2022)
- Decision and order granting State of New York motion for appointment of an Independent Monitor (Nov. 3, 2022)
Article 78 Petition against Justice Engoron
- Defendant withdrawal of Article 78 petition against Justice Engoron (Oct. 5, 2023)
- First Department appellate court decision lifting its Sept. 14 temporary stay of trial and denying Article 78 petition, allowing Oct. 2 trial date to proceed (Sept. 28, 2023)
- Deputy Solicitor General Judith N. Vale affirmation in opposition to defendants application for interim stay pending review of Article 78 petition (Sept. 20, 2023)
- Affirmation of defendants counsel Clifford S. Robert in further support of joint Article 78 petition (Sept. 24, 2023)
- First Department appellate court decision granting temporary stay of trial pending appellate review (Sept. 14, 2023)
- Justice Engoron response and notice pursuant to CPLR § 7804(i) (Sept. 20, 2023)
- Defendants application for interim stay pending review of Article 78 petition (Sept. 13, 2023)
- Defendants Article 78 petition to First Department against Justice Engoron (Sept. 13, 2023)
- Justice Engoron order declining to sign proposed order to show cause as "completely without merit" (Sept. 6, 2023)
Defendants’ November 2022 Motions to Dismiss the Complaint
Donald J. Trump and Eric Trump
- First Department appellate decision modifying decision and order denying motion to dismiss (in so far as the Tolling Agreement), and finding claim against Ivanka Trump time-barred (June 27, 2023)
- Donald Trump and Eric Trump appeal to First Department of decision and order denying motion to dismiss (Feb. 3, 2023)
- Decision and order denying Donald Trump and Eric Trump motion to dismiss complaint (January 9, 2023)
- Donald Trump and Eric Trump notice of motion to dismiss the complaint (Nov. 21, 2022)
Trump Organization Inc., Trump Organization LLC, and Donald J. Trump
- First Department appellate decision modifying decision and order denying motion to dismiss (in so far as the Tolling Agreement), and finding claim against Ivanka Trump time-barred (June 27, 2023)
- Donald J. Trump, Allen Weisselberg, Jeffrey McConney, The Donald J. Trump Revocable Trust, The Trump Organization, Inc., Trump Organization LLC, DJT Holdings LLC, DJT Holdings Managing Member, Trump Endeavor 12 LLC, 401 North Wabash Venture LLC, Trump Old Post Office LLC, 40 Wall Street LLC, and Seven Springs LLC appeal to First department of decision and order denying motion to dismiss (Feb. 3, 2023)
- Decision and order denying motion to dismiss complaint by Trump Organization Inc., Trump Organization LLC, and Donald J. Trump (January 9, 2023)
- Notice of motion to dismiss complaint by Trump Organization Inc., Trump Organization LLC, and Donald J. Trump (Nov. 21, 2022)
Allen Weisselberg and Jeffrey McConney
- First Department appellate decision modifying decision and order denying motion to dismiss (in so far as the Tolling Agreement), and finding claim against Ivanka Trump time-barred (June 27, 2023)
- Donald J. Trump, Allen Weisselberg, Jeffrey McConney, The Donald J. Trump Revocable Trust, The Trump Organization, Inc., Trump Organization LLC, DJT Holdings LLC, DJT Holdings Managing Member, Trump Endeavor 12 LLC, 401 North Wabash Venture LLC, Trump Old Post Office LLC, 40 Wall Street LLC, and Seven Springs LLC appeal to First department of decision and order denying motion to dismiss (Feb. 3, 2023)
- Decision and order denying motion to dismiss complaint by Allen Weisselberg and Jeffrey McConney (January 9, 2023)
- Notice of motion to dismiss complaint by Allen Weisselberg and Jeffrey McConney (Nov. 21, 2022)
Ivanka Trump
- First Department appellate decision modifying decision and order denying motion to dismiss (in so far as the Tolling Agreement), and finding claim against Ivanka Trump time-barred (June 27, 2023)
- Ivanka Trump appeal to First department of decision and order denying motion to dismiss (Feb. 3, 2023)
- Decision and order denying Ivanka Trump motion to dismiss complaint (January 9, 2023)
- Ivanka Trump notice of motion to dismiss complaint (Nov. 21, 2022)
- Memorandum of law in support of Ivanka Trump motion to dismiss complaint (Nov. 21, 2022)
- Affirmation of counsel Clifford S. Robert in support of motion to dismiss complaint (Nov. 21, 2022)
The Donald J. Trump Revocable Trust, DJT Holdings Managing Member, Trump Endeavor 12 LLC, and 401 North Wabash Venture LLC
- First Department appellate decision modifying decision and order denying motion to dismiss (in so far as the Tolling Agreement), and finding claim against Ivanka Trump time-barred (June 27, 2023)
- Donald J. Trump, Allen Weisselberg, Jeffrey McConney, The Donald J. Trump Revocable Trust, The Trump Organization, Inc., Trump Organization LLC, DJT Holdings LLC, DJT Holdings Managing Member, Trump Endeavor 12 LLC, 401 North Wabash Venture LLC, Trump Old Post Office LLC, 40 Wall Street LLC, and Seven Springs LLC appeal to First department of decision and order denying motion to dismiss (Feb. 3, 2023)
- Decision and order denying motion to dismiss complaint by (i) The Donald J. Trump Revocable Trust; (ii) DJT Holdings Managing Member; (iii) Trump Endeavor 12 LLC; And (iv) 401 North Wabash Venture LLC (January 9, 2023)
- Notice of motion to dismiss complaint by (i) The Donald J. Trump Revocable Trust; (ii) DJT Holdings Managing Member; (iii) Trump Endeavor 12 LLC; And (iv) 401 North Wabash Venture LLC (Nov. 21, 2022)
- Affirmation of counsel Alina Habba in support of motion to dismiss complaint (Nov. 21, 2022)
- Memorandum of law in support of motion to dismiss complaint by (i) The Donald J. Trump Revocable Trust; (ii) DJT Holdings Managing Member; (iii) Trump Endeavor 12 LLC; And (iv) 401 North Wabash Venture LLC (Nov. 21, 2022)
DJT Holdings LLC, Trump Old Post Office LLC, 40 Wall Street LLC, and Seven Springs LLC
- First Department appellate decision modifying decision and order denying motion to dismiss (in so far as the Tolling Agreement), and finding claim against Ivanka Trump time-barred (June 27, 2023)
- Donald J. Trump, Allen Weisselberg, Jeffrey McConney, The Donald J. Trump Revocable Trust, The Trump Organization, Inc., Trump Organization LLC, DJT Holdings LLC, DJT Holdings Managing Member, Trump Endeavor 12 LLC, 401 North Wabash Venture LLC, Trump Old Post Office LLC, 40 Wall Street LLC, and Seven Springs LLC appeal to First department of decision and order denying motion to dismiss (Feb. 3, 2023)
- Decision and order denying motion to dismiss complaint by: (i) DJT Holdings LLC; (ii) Trump Old Post Office LLC; (iii) 40 Wall Street LLC; and (iv) Seven Springs LLC (January 9, 2023)
- Notice of motion to dismiss complaint by (i) DJT Holdings LLC; (ii) Trump Old Post Office LLC; (iii) 40 Wall Street LLC; and (iv) Seven Springs LLC (Nov. 21, 2022)
Sanctions
- State of New York notice of motion for sanctions against defendants pursuant to 22 N.Y.C.R.R. § 130-1.1 (Sept. 5, 2023)
Other Matters
- Non-party Ivanka Trump notice of motion for an order quashing subpoenas served on TTT Consulting LLC, Ivanka OPO LLC, and 502 Park Project, or, in the alternative, a protective order (Oct. 19, 2023)
- State of New York letter to court on admissibility of parts of Patrick Birney testimony on Allen Weisselberg statements regarding Trump (Oct. 17, 2023)
Key Statutes
- Persistent and Repeated Business Fraud, New York Executive Law § 63(12)
- Falsifying Business Records, New York Penal Law § 175.10
- Issuing a False Financial Statement, New York Penal Law § 175.45
- Insurance Fraud, New York Penal Law § 176.05
Just Security Writings
- Norman L. Eisen, The NY Trump Civil Fraud Trial: From Tipping Point to Toppling Over, Just Security (Oct. 3, 2023)
- E. Danya Perry, Joshua Stanton and Norman L. Eisen, Has a Trump Tipping Point Been Reached? Analyzing The NY Attorney General’s Case Against Trump, Just Security (Sept. 21, 2022)
Media and Other Resources
- Ruth Marcus, Does the New York fraud case against Trump go too far?, Washington Post (Oct. 3, 2023)
- Emily Shapiro, Peter Charalambous, Aaron Katersky, and Olivia Rubin, Trump fraud trial live updates, ABC News (Oct. 2, 2023)
- NBC News, Trump fraud trial live updates: What's happening inside the courtroom, (Oct. 2, 2023)
- Reuters, Donald Trump’s civil fraud trial: a timeline of key moments in case, (Oct. 2, 2023)
Selected Trump Statements
- Donald Trump, Truth Social Criticizing NY Executive Law 63, Truth Social (Oct. 3, 2023)
- Donald Trump, Truth Social calling AG James “Deranged”, Truth Social (Oct. 3, 2023)
- Donald Trump, Truth Social “People are starting to see what a great company I built through the trial”, Truth Social (Oct. 3, 2023)
- Donald Trump, Trump makes statement prior to entering courtroom in civil fraud trial, ABC News (Oct. 2, 2023)