INDEX NO. 451130/2018

FILED: NEW YORK COUNTY CLERK 06/14/2018 09:58 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/14/2018

SUPREME

COURT

COUNTY
THE

PEOPLE

BARBARA

OF THE
D.

of New

State

OF THE

STATE

NEW YORK

OF

NEW YORK

OF

STATE

OF

UNDERWOOD,

NEW

Attorney

YORK,

by

General

of the
Index

York,

No.

Petitioner,
-against-

VERIFIED

DONALD

DONALD

J. TRUMP,

IVANKA

ERIC

TRUMP,

J. TRUMP

J. TRUMP

F. TRUMP,

PETITION

JR.,

DONALD

THE

and

FOUNDATION,
Respondents.

the

Petitioner,

General

of the

People

of the

of New

State

State

of New

York,

for

Petition,

as and

York,

her

PRELIMINARY
For

1.

violation

persistent

illegal

conduct

political

not-for-profit

Foundation

than

state

authorized

by

Donald

with

June

J. Trump

2016,

Foundation

the

law

governing

board

this

Foundation

New

members

York

Attorney

special

board

members

York

law,

to obtain

General

from

future

restitution

in the

lawful

and

to follow

formalities

required

service

and

the

law.

by

Foundation

penalties,

of

of

basic

as a director

distribution

pattern

extensive

failure

to dissolve

proceeding

in

This

charities.

improper

and

corporate

elementary

operated

has

State

includes

transactions,

its

Attorney

Underwood,

alleges:

respectfully

J. Trump

self-dealing

brings

New

Donald

even

D.

STATEMENT

the

its

willful

enjoin

charitable

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and

implement

conduct,

to qualified

federal

therefore

to cooperate

2.

and

and

or to

General

a decade,

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repeated

illegal

persistently

the

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obligations

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assets

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by

activity,

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more

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by

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of

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any

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the

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began

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"Foundation")

an investigation

pursuant

1

1 of 41

to the

New

(the

York

"Investigation"
"Investigation")

Not-for

Profit

of

 INDEX NO. 451130/2018

FILED: NEW YORK COUNTY CLERK 06/14/2018 09:58 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/14/2018

Law

Corporation

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of

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pursuant

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the

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11 of the

of

 INDEX NO. 451130/2018

FILED: NEW YORK COUNTY CLERK 06/14/2018 09:58 AM
NYSCEF DOC. NO. 1

N-PCL

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and

to the

(i)

RECEIVED NYSCEF: 06/14/2018

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service

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charitable

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charities;

any

corporate

relief

as the

 INDEX NO. 451130/2018

FILED: NEW YORK COUNTY CLERK 06/14/2018 09:58 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/14/2018

THE
5.

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under

at

 INDEX NO. 451130/2018

FILED: NEW YORK COUNTY CLERK 06/14/2018 09:58 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/14/2018

8.

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from

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distribute

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 INDEX NO. 451130/2018

FILED: NEW YORK COUNTY CLERK 06/14/2018 09:58 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 06/14/2018

14.

of

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self-dealing

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 INDEX NO. 451130/2018

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NYSCEF DOC. NO. 1

and

RECEIVED NYSCEF: 06/14/2018

in the

pay,

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 INDEX NO. 451130/2018

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22.

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to N-PCL

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injunction

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NYSCEF DOC. NO. 1

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NYSCEF DOC. NO. 1

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NYSCEF DOC. NO. 1

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 INDEX NO. 451130/2018

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Assistant
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 INDEX NO. 451130/2018

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NYSCEF DOC. NO. 1

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VERIFICATION

STATE

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STEVEN

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the

the

my knowledge

upon

investigative

authorized

t

13th

y of

b

alleged

which

to

on

based

therein

the

petition

is

with

the

Foundation

materials

this

verification

is its

is not

duly

made

authorized

by

petitioner

such

contained

acquaintance

petitioner

is that

representative.

,

S

ff
ttorney

PUBLIC

Sworn

facts

J. Trump

Assistant

d

Underwood,

I am duly

transactions

Steven

NOTARY

D.

in

with

is true.

General

Attorney

and

investigation

General's

Attorney

reason

petition

foregoing

Attorney

Bureau

The

and

being

verification.

I have

Charities

}

ore

me this

June,

2018

EMn.Y STEfW
Yoek
NOTARY PUGUC, State of New
No. 02ST5056697
QuaRAed In Kings County
2D
Commission Expiree Memh

m

41

41 of 41

General

is a body

politic