The United States of America  v.  Donald J Trump, Paul Manafort, Jared Kushner, and Michael Flynn

Dear Special Counsel- here is a rough draft. Hope it helps. Robb 
United States of America

v

Donald J Trump, Aka “the Donald”, Paul Manafort, Jared Kushner, Michael Flynn Defendants 

            INDICTMENT (Draft)

The Grand Jury Charges: From a period beginning on or about June 16. 2015, to on or about, June 9, 2017, Donald J Trump,  Paul Manafort, Jared Kushner, Michael Flynn and others, known and unknown to the grand jury, did knowingly and intentionally conspire  to engage in treason, engaged in violations of the Emoluments Clause, engaged in obstruction of justice and made false statements to federal agents  . The scheme of these defendants was as follows:

1. Donald J Trump, a reality tv star, ran for President of the United States. Trump and his co-conspirators’ goal was for Trump to win the election and then use the position of the Presidency to illegally enrich himself and his co-conspirators in violation of 18 USC 371.

2. Donald J Trump and his  co-conspirators held numerous meetings with representatives of the Russian Government.  When questioned by federal agents about said meetings, the  co-conspirators each concealed the existence of these meetings  in violation of 18 USC 1001. During these meetings the Russian government agreed to provide illegal aid to Trump in the election. In exchange, Trump and his co-conspirators acting against the interests of the United States, agreed to lift United States’ sanctions against Russia. Trump, Manafort, Kushner and Flynn conspired with the Russian Government to interfere with the United States presidential election in an effort to turn the election in Trump’s favor. Trump and his  co-conspirators  met with representatives of the Russian Government against the interests of the United States and thereby committed the offense of treason.

3. Donald J Trump, openly, repeatedly and publicly encouraged Russia to illegally hack the computer of Trump’s opponent and release potentially embarrassing emails in an effort to win the election. In response, the Russian Government did knowingly illegally hack the computer of Trump’s opponent and the Democratic National Committee. Trump and his   co-conspirators colluded with the Russian government in an effort to maximize the damage done to Trump’s opponent by said public releases.
4. Donald J Trump, with the illicit aid of the Russian Government, won the election. Trump rewarded the Russian Government for their illegal actions  by directing American foreign policy in such a manner as to aid the Russian Government in its global aspirations while alienating longtime Allies of the United States. 
5. In furtherance of the conspiracy , Donald J Trump and his  co-conspirators , at all times operated in direct violation of the Emoluments clause. Trump and his  co-conspirators and family utilized Trump’s position to illegally enrich themselves. Trump, his  co-conspirators and his family sold influence in exchange for large sums of money. 
6. When an investigation began into Trump’s collusion with Russia, Trump personally obstructed the investigation. Trump asked the Director  of the FBI to stop the investigation into co-conspirator Michael Flynn. When the Directer refused to stop the investigation, Trump fired the Director of the FBI in retaliation. 
7. Trump continued to collude with Russia in direct contravention with the best interests of The United States. Trump shared top secret information with Russian agents, thereby endangering an intelligence asset of an Ally of the United States. Trump continued to engage in treason, to daily violate the Emoluments clause and to daily attempt to obstruct the investigation by attempting to intimidate witnesses against him and his co-conspirators.
All of the Above acts were done in violation of Federal laws.
____________________________

Foreman of the Grand Jury

About Robert Fickman

Robert Fickman is a criminal defense attorney with 33 years experience in defending the citizen accused in both state and federal court. He is a past president of HCCLA and remains active in its mission.

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