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