Clearinghouse: New York Attorney General Corporate Fraud Case

Summons and Complaint

• State of New York summons and complaint (Sept. 21, 2022)

Ongoing Consolidated Appeal of Summary Judgment and Final Decision and Judgment, NY First Department Appeal, Case No.: 2023-04925

Appeal of Summary Judgment and Final Decision and Judgment (Consolidated Appeal), NY First Department Appeal, Case No.: 2023-04925

• Defendants joint reply brief in support of appeal from summary judgment and final decision and judgment (Aug. 30, 2024)
• Non-party appellants joint reply brief in support of appeal from sanctions imposed in summary judgment (Aug. 30, 2024)
• State of New York corrected respondent brief to (1) defendants joint appeal from summary judgment and final decision ad judgment, and (2) non-party appeal from sanctions imposed in summary judgment (Aug. 27, 2024) [entered Aug. 29] 
• Defendants joint brief in support of appeal from summary judgment and final decision and judgment (July 22, 2024)
• Brief of non-party appellants against sanctions imposed on them in summary judgment (July 22, 2024)
• Non-party appellants joint reply brief in support of appeal from sanctions imposed in summary judgment (Aug. 30, 2024)
• State of New York corrected respondent brief to (1) defendants joint appeal from summary judgment and final judgment, and (2) non-party appeal from sanctions imposed in summary judgment (Aug. 27, 2024) [entered Aug. 29] 
• Defendants joint brief in support of appeal from summary judgment and final judgment (July 22, 2024)
• Brief of non-party appellants against sanctions imposed on them in Justice Engoron Sept. 26, summary judgment (July 22, 2024)

Appeal of Final Decision and Judgment (Pre-Consolidation), NY First Department Appeal, Case No.: (2024-01134 & 2024-01135) 

• Order denying State of New York motion to dismiss defendants appeal of summary judgment, but granting motion to consolidate briefing on their appeal and appeals by non-party appellants against sanctions (June 25, 2024)
• Trump filing confirming having posted a $175 million undertaking on appeal (April 1, 2024)
• Order granting in part Trump motion to stay Engoron judgment pending appeal – all portions of the judgment stayed except (1) extending and enhancing the role of the Monitor and (2) directing the installation of an Independent Director of Compliance, so long as Trump posts an undertaking of $175 million by April 4 (March 25, 2024)
• State of New York affirmation in surreply to defendants motion for a stay pending appeal (March 22, 2024)
  • Court grants State of New York letter seeking permission to file a surreply to defendants motion for a stay pending appeal (March 22, 2024)
  • Defendants response letter to State of New York letter seeking permission to file a surreply to defendants motion for a stay pending appeal (March 21, 2024)
  • State of New York letter seeking permission to file a surreply to defendants motion for a stay pending appeal (March 20, 2024)
  • State of New York letter seeking permission to file a surreply to defendants motion for a stay pending appeal (and exhibited proposed affirmation in surreply) (March 20, 2024) [this filing was later deleted from the docket, with the state filing an amended letter seeking permission to file, receiving permission and filing the surreply again, as above]
• Defendants reply memorandum of law in support of application for stay pending appeal of Feb. 16 decision and order and Feb. 23 final judgment (March 17, 2024) [e-filed March 18]
  • Affirmation in support of defendants reply memorandum of law in support of application for stay pending appeal of Feb. 16 decision and order and Feb. 23 final judgment (March 18, 2024)
• State of New York memorandum of law in opposition to application for stay pending appeal of Feb. 16 decision and order and Feb. 23 final judgment (March 11, 2024)
• Order granting defendants application for interim stay of final judgment pending appeal in respect of all matters sought except enforcement of the fine imposed, and setting briefing and oral argument (Feb. 28, 2024)
  • State of New York opposition to defendants joint emergency application for an interim stay pending appeal of Feb. 16 decision and order and Feb. 23 final judgment (Feb. 28, 2024)
  • Defendants joint emergency application for an interim stay pending appeal of Feb. 16 decision and order and Feb. 23 final judgment, including order to show cause, exhibits (and memorandum of law in support) (Feb. 28, 2024)
  • Defendants notice of appeal of Feb. 23 judgment (Feb. 26, 2024)
  • Defendants notice of appeal of Feb. 16 decision and order (Feb. 26, 2024)

Appeal of Summary Judgment (Pre-Consolidation), NY First Department Appeal, Case No.: 2023-04925

• Order denying State of New York motion to dismiss defendants appeal of summary judgment, but granting motion to consolidate briefing on their appeal and appeals by non-party appellants against sanctions (June 25, 2024)
  • Non-party appellants affirmation in opposition to State of New York motion to dismiss or, in the alternative, consolidate briefing (June 14, 2024) 
  • Defendants memorandum of law in opposition to State of New York motion to dismiss or, in the alternative, consolidate briefing (June 13, 2024) [entered June 14]
  • Affirmation of Armen Morian in support of defendants memorandum of law in opposition to State of New York motion to dismiss or, in the alternative, consolidate briefing (June 14, 2024) 
  • State of New York notice of motion to dismiss defendants appeal of summary judgment or, in the alternative, to consolidate briefing on their appeal and appeals by non-party appellants against sanctions (and exhibits) (June 7, 2024) 

• Order setting new briefing schedule to perfect appeals against summary and final judgment (June 20, 2024)

• Order denying counsel for defendants (non-party appellants) motion to sever their appeal against sanctions imposed on them in Justice Engoron Sept. 26 summary judgment (March 14, 2024)
  • Memorandum of law in further support of counsel for defendants (non-party appellants) motion to sever their appeals against sanctions imposed on them in Justice Engoron Sept. 26 summary judgment (Feb. 16, 2024)

• • State of New York affirmation in response to counsel for defendants motion to sever their appeals against sanctions imposed on them in Justice Engoron Sept. 26, summary judgment (Feb. 13, 2024)
  • Counsel for defendants (non-party appellants) motion to sever their appeal against sanctions imposed on them in Justice Engoron Sept. 26 summary judgment (Jan. 23, 2024)=

• First Department appellate court denying defendants motion for a stay of Justice Engoron Sept. 26 and Oct. 4 orders on summary judgment, and stay of trial, pending appeal (Dec. 7, 2023)
  • 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)

Surety on Undertaking 

• Order granting proposed order to show cause, setting hearing for April 22 at 10 AM (April 16, 2024)
• Knight Specialty Insurance Company and defendants joint memorandum of law in support of order to show cause to justify KSIC as surety on the undertaking, to set aside the State of New York notice of exception to surety, and to award costs incurred by the application (April 15, 2024)
  • Knight Specialty Insurance Company and defendants proposed joint order to show cause to justify KSIC as surety on the undertaking, to set aside the State of New York notice of exception to surety, and to award costs incurred by the application (April 15, 2024) 
  • Affirmation of Amit Shah in support of motion by Knight Specialty Insurance Company and defendants for an order to show cause to justify KSIC as surety on the undertaking, to set aside the State of New York notice of exception to surety, and to award costs incurred by the application (April 15, 2024)
  • Affirmation of Gregory V. Serio in support of motion by Knight Specialty Insurance Company and defendants for an order to show cause to justify KSIC as surety on the undertaking, to set aside the State of New York notice of exception to surety, and to award costs incurred by the application (April 15, 2024)
  • David H. Pikus affirmation of urgency in support of motion by Knight Specialty Insurance Company and defendants for an order to show cause to justify KSIC as surety on the undertaking, to set aside the State of New York notice of exception to surety, and to award costs incurred by the application (April 15, 2024)
  • Exhibits in support of joint application to set aside the State of New York exception to surety and to justify surety (April 15, 2024) 

• State of New York notice of exception to the sufficiency of the surety on the undertaking issued by Knight Specialty Insurance Company (April 4, 2024)
• Trump filing confirming having posted a $175 million undertaking on appeal (April 1, 2024)

Final Decision and Judgment

• Final judgment of Justice Engoron (Feb. 22, 2024) [e-filed Feb. 23]
• Emails between defense counsel, State of New York and Justice Engoron regarding the proposed judgment and stay of enforcement (Feb. 21-22, 2024)
• Defendants letter responding to Justice Engoron Feb. 21 email (Feb. 21, 2024)
  • Justice Engoron email to defendants on there being no need for a motion or conference and directing defendant to inform the court of any specific objections to proposed judgment and how counter judgment would differ (Feb. 21, 2204)
• Amended State of New York proposed final judgment (Feb. 21, 2024)
  • Defendants letter in response to State of New York proposed final judgment (Feb. 21, 2024)
• State of New York proposed final judgment (Feb. 20, 2024)
• Decision and order of Justice Engoron after non-jury trial (Feb. 16, 2024)

Summary Judgment 

• 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) 
  • State of New York letter to the Court concerning the Defendants’ proposed order to show cause (Nov. 16, 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]
  • State of New York memorandum of law in support of partial summary judgment (Aug. 30, 2023)
  • Defendants memorandum of law in support of motion for summary judgment (Aug. 30, 2023)
    • Defendants statement of undisputed material facts in support of joint motion for summary judgment (Aug. 30, 2023)

Recusal

• Justice Engoron order denying motion for him to recuse, or, in the alternative, an evidentiary hearing before another judge (July 25, 2024)
• State of New York memorandum of law in opposition to defendants motion for recusal of Justice Engoron, or, in the alternative, an evidentiary hearing before another judge  (June 26, 2024)
• Defendants memorandum of law in support of motion for recusal of Justice Engoron, or, in the alternative, an evidentiary hearing before another judge  (June 20, 2024)
  • Affirmation of Armen Morian in support of defendants motion for recusal of Justice Engoron, or, in the alternative, an evidentiary hearing before another judge (June 21, 2024)
  • Affirmation of Clifford S. Robert in support of defendants motion for recusal of Justice Engoron, or, in the alternative, an evidentiary hearing before another judge (June 20, 2024)

Independent Monitor 

• State of New York response to defendants opposition letters to their request for modification to the March 21 Monitorship order (April 9, 2024)
  • Weisselberg letter adopting other defendants letter opposing the State of New York request to modify the Monitorship order (April 8, 2024)
  • Defendants letter opposing the State of New York request to modify the Monitorship order (April 8, 2024)
  • State of New York letter requesting two modifications to the March 21 Monitorship order (April 4, 2024)
• Order on continued independent monitorship of 3 years (March 21, 2024)
• Donald Trump Jr. and Eric Trump letter in response to Jan. 26 letter by Independent Monitor Barbara Jones confirming deficiencies in financial information (Jan. 29, 2024)
  • Independent Monitor Barbara Jones letter to Justice Engoron confirming “certain deficiencies in the financial information…reviewed, including disclosures that are either incomplete, present results inconsistently, and/or contain errors” (Jan. 26, 2024)
• Independent Monitor Barbara Jones report on status of monitorship (Nov. 29, 2023)
• 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)

Supplemental Briefing re Allen Weisselberg perjury prosecution

• Response letter from Justice Engoron to Clifford Robert (Feb. 8, 2024)
• State of New York response (Feb. 7, 2024)
• Clifford Robert response (Feb. 7, 2024)
• Alina Habba response (Feb. 7, 2024)
• Letter from Justice Engoron to counsel asking for briefing regarding NY Times report that Allen Weisselberg is negotiating with the Manhattan prosecutors to plead guilty to perjury (Feb. 5, 2024) [e-filed Feb. 6]

Final Briefs and Closing Arguments

• Donald Trump Jr. and Eric Trump response to State of New York notice of supplemental authority (Jan. 24, 2024) 
  • State of New York notice of supplemental authority – Fed. Trade Comm’n v. Shkreli, 2d Cir. No. 22-72 – following closing arguments (Jan. 23, 2024)
• Defendants (other than Donald Trump Jr. and Eric Trump) closing argument presentation (Jan. 11, 2024) [e-filed Jan. 22]
• Donald Trump Jr. and Eric Trump closing argument presentation (Jan. 11, 2024) [e-filed Jan. 22]
• Transcript excerpt of Trump addressing Justice Engoron during Jan. 11 closing arguments (exhibited in E. Jean Carroll v. Donald J. Trump (1:20-cv-07311)) (Jan. 11, 2024) [e-filed Jan. 12]
• State of New York closing argument presentation (Jan. 11, 2024)
• Email correspondence between Justice Engoron and Trump counsel regarding closing arguments and Trump request to participate (Jan. 3-10, 2024)
• State of New York proposed findings of fact and conclusions of law (Jan. 5, 2024)
• Donald Trump Jr. & Eric Jr proposed conclusions of law (Jan. 5, 2024)
• Donald Trump Jr. & Eric Jr proposed findings of fact (Jan. 5, 2024)
• Trump, Weisselberg et al proposed conclusions of law (Jan. 5, 2024)
• Trump, Weisselberg et. al. proposed findings of fact (Jan. 5, 2024)
• Application of News Organizations for audiovisual coverage of Jan. 11 closing arguments (Jan. 4, 2024)

Transcripts of Proceedings

• Transcripts of Proceedings (November 13, 2023 to November 17, 2023) (Jan. 4, 2024)
• Transcripts of Proceedings (November 20, 2023 to November 21, 2023) (Jan. 4, 2024) 
• Transcripts of Proceedings (November 27, 2023 to December 1, 2023) (Jan. 4, 2024)
• Transcripts of Proceedings (December 4, 2023 to December 8, 2023) (Jan. 4, 2024)
• Transcripts of Proceedings (December 12, 2023 to December 13, 2023) (Jan. 4, 2024)

Gag Orders

NY First Department Appeal, Case No.: 2023-05859

• Trump notice of appeal of First Department appellate decision denying defendants application for leave to appeal by permission to the New York Court of Appeals of Nov. 30 order denying joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Dec. 15, 2023)
• First Department appellate court decision denying defendants application for leave to appeal by permission to the New York Court of Appeals of Nov. 30 order denying joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Dec. 14, 2023)
• First Department appellate court order denying defendants application for leave to appeal by permission to the New York Court of Appeals of Nov. 30 order denying joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Dec. 14, 2023) 
• State of New York letter to court providing a copy of D.C. Circuit decision upholding but narrowing Judge Chutkan order limiting Trump extrajudicial prejudicial statements (Dec. 11, 2023)
• State of New York affirmation in opposition to defendants application for leave to appeal by permission to the New York Court of Appeals of Nov. 30 order denying joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Dec. 10, 2023) 
• Justice Engoron counsel affirmation in opposition to defendants application for leave to appeal by permission to the New York Court of Appeals of Nov. 30 order denying joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Dec. 10, 2023) 
• State of New York response in opposition to defendants Article 78 petition (Dec. 6, 2023)
• Defendants letter waiving right to submit reply in support of Article 78 petition (Dec. 6, 2023)
• Justice Engoron counsel answer and affirmation in opposition to defendants Article 78 petition (Dec. 6, 2023)
• First Department appellate court order denying defendants application for interim relief and interim application for a preference, but granting application for an expedited briefing schedule on application for expedited leave to appeal by permission to the New York Court of Appeals of Nov. 30 order denying joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump (Dec. 4, 2023)
• Defendants proposed order to show cause for expedited leave to appeal by permission to the New York Court of Appeals of Nov. 30 order denying joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump, including summary statement on application, affirmation of urgency in support, and exhibits (Dec. 3 & 4, 2023) 
• First Department appellate court order denying defendants joint Article 78 petition against Justice Engoron gag orders and findings of contempt against Donald Trump, and vacating Nov. 16 interim stay (Nov. 30, 2023)
• 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, Motions in Limine, and Witnesses 

• Decision and order denying defendants’ motions for a directed verdict (Dec. 18, 2023)
  • State of New York letter in response to defendants’ letter motion for a directed verdict (Dec. 18, 2023)
  • Defendants letter in support of on the record motions for a directed verdict (Dec. 15, 2023)
  • Defendants filed PowerPoint presentation from Nov. 9 on the record motion for a directed verdict (Nov. 9, 2023) [e-filed Dec. 15] 
• Defendants letter in support of application to preclude testimony from the State of New York proposed rebuttal witness, Eric Lewis (Dec. 12, 2023)
• Defendants letter in support of application to preclude testimony from the State of New York proposed rebuttal witnesses, Kevin Sneddon and Eric Lewis (Dec. 12, 2023)
• Defendants letter to court notifying intent to call expert witness Lawrence Moens (Dec. 1, 2023)
  • Expert rebuttal report of defendants expert witness Lawrence Moens, dated June 30, 2023 (Dec. 1, 2023)
  • Expert report of defendants expert witness Lawrence Moens, dated May 26, 2023 (Dec. 1, 2023) (Dec. 1, 2023)
• Defendants letter to court providing authority for their Nov. 27 request to call Independent Monitor Barbara Jones as a witness following Justice Engoron denial in open court (Dec. 1, 2023) 
  • Exhibited transcript of Nov. 27 proceedings in which Justice Engoron denied defendants request to call Independent Monitor Barbara Jones as a witness (Dec. 1, 2023)
• Defendants letter to court notifying intent to call expert witness John K. Shubin (Dec. 1, 2023)
  • Expert opinion of defendants expert witness John K. Shubin regarding covenants, restrictions and zoning for Mar-a-Lago property, dated June 30, 2023 (Dec. 1, 2023)
  • Curriculum Vitae of defendants expert witness John K. Shubin (Dec. 1, 2023)
• Order denying motion to quash subpoenas regarding non-party Ivanka Trump (Nov. 16, 2023) [e-filed Nov. 17]
  • 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 memorandum of law in support of motion in limine to preclude expert testimony of Michie; McCarty (Oct. 30, 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)
    • Memorandum of law in support of defendants’ joint motion 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

• Confidentiality order limiting the review, copying, dissemination and filing of confidential and/or proprietary documents and information (Dec. 1, 2022)

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)

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)
  • Defendants amended notice of Article 78 petition to First Department against Justice Engoron (Sept. 14, 2023)
• Justice Engoron order declining to sign proposed order to show cause as "completely without merit" (Sept. 6, 2023)
  • Defendants memorandum of law in support of order to show cause to briefly stay trial (Sept. 5, 2023)

Defendants’ November 2022 Motions to Dismiss the Complaint

Donald Trump Jr. 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 Jr. and Eric Trump appeal to First Department of decision and order denying motion to dismiss (Feb. 3, 2023) 
• Decision and order denying Donald Trump Jr. and Eric Trump motion to dismiss complaint (January 9, 2023)
• Donald Trump Jr. and Eric Trump notice of motion to dismiss the complaint (Nov. 21, 2022)
  • Memorandum of law in support of Donald Trump Jr. and Eric Trump motion to dismiss the complaint (Nov. 21, 2022)
  • Affirmation of counsel Clifford S. Robert in support of motion to dismiss 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)
  • Affirmation of counsel Alina Habba in support of motion to dismiss complaint (Nov. 21, 20220
  • Memorandum in support 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)
  • 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 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)
  • 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) 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

• Weisselberg counsel counsel to change attorneys from Habba Madaio & Associates LLP to Morian Law PLLC (April 7, 2024) 
• Intervenor-Defendant Robert S. Stone Jr. notice of appeal of Feb. 27 decision and order for failing to address facts necessitating dismissal for lack of jurisdiction (March 4, 2024) [e-filed March 17]
  • Order denying Robert S. Stone Jr. motion to intervene (Feb. 27, 2024)
  • Robert S. Stone Jr. memorandum of law in reply to State of New York memorandum of law in support of opposition to his motion to intervene (Jan. 25, 2024)
  • State of New York memorandum of law in support of opposition to notice of motion to intervene by Robert S. Stone Jr. (Jan. 23, 2024)
  • Notice of motion to intervene by Robert S. Stone Jr. (Jan. 17, 2024)
  • Affirmation in support of motion to intervene by Robert S. Stone Jr. (Jan. 17, 2024)
  • Proposed order by movant Robert S. Stone Jr. (Jan. 17, 2024)
  • Copy of Robert S. Stone Jr.  complaint filed Jan. 15 against AG Letitia James et al. filed in Suffolk County Supreme Court (Jan. 17, 2024)
• State of New York letter to court on likely omissions from defendants production, requesting the Independent Monitor to carry out a forensic examination of electronic data held by Trump Organization between August and September 2016 (Oct. 18, 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)
  • Donald Trump and Eric Trump counsel letter to court on inadmissibility of parts of Patrick Birney testimony on Allen Weisselberg statements regarding Trump (Oct. 19, 2023)

• 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

• Adam Klasfeld, Trump’s ‘Ill-Gotten Gains’: Breaking Down the $464M Civil Fraud Appeal, Just Security (April 2, 2024) 
• 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)

• Norman L. Eisen, Joshua Kolb and Andrew Warren, Trump’s New York Civil Trial Is Only One Aspect of His Massive Fraud, Daily Beast (Jan. 11, 2024)
• Andrew Warren and Norman L. Eisen, Did New York Prove Its Civil Fraud Case Against Trump? A Comprehensive Analysis, SSRN (Jan. 11, 2024)
• Norman L. Eisen and Samara Angel, Even Trump realized his testimony in New York was a mistake, MSNBC (Nov. 8, 2023)
• 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)

• 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)