LETITIA JMIES 

ATTORNEY GENERAL 

November 3,2022 

Hon .. Arthur Engoron 

STATE OF NEW YORK 

OFFICE OF THE AT:rdRNEY GENERAL 

28 LIBERTY STREET 

NEW"YORK, NY 10005 

Supreme Court, New York County 

60 Centre StJ:eet 

NewYork,NY 10007 

RE: People v. Donald J. Trnmp, ~tal. - Index No. 452564/2022 

Dear Justice Engoron, 

The Office of the Atto1ney General ("OAG'')writes in advance of this morning's hearing 

to ale1i the Comt to an important and highly relevant development. According to asociaLmedia 

post last night, Mr. Tnunp has filed suitagainsttheNewYorkAttomey General in a Florida 

state comtseeking, again, to flllstrate OAG's investigation and··this enforcement action("Horida 

Comp 1. ''). 1 

This development puts beyond doubt that preliminary relief is wananted here fora few 

reasons. First, Mr. Tmmp is, ·ill. fact, atten1ptilig to·. shield· the key docm11ents goven1ing · the 

stmcture of his business conglomerate and ownership of.his business assets from review. In 

particular, Mr. Tnunp asserts fl)egaLrighrto shieldJi:om scmtiny tlle d.oc11n1ents g9veμiing the 

Donald J. Tmmp Revocable Tmst (the "Tmst"), see, e.g., Florida Compl. ,I 118, despite, as this 

Court knows, having co11se11ted t9 this Comf,s jurisdiction over investigative subpoena 

enforcement These documents are of obvious relevance; not only do they pertain to the merits, 

but they also pertain to ownership and control of the business, assets and thus to available relief. 2 

1 Attached is a copy ofthe complaint thatpurpotts to have been filedin tl1e Circuit Comt of the 

Fifteenth Judicial I)istrict in Palm Beach County, CivilDivision. 

2 As has been noted, the Tmst is the vehicleJhrough which the Statements of Financial Condition 

were issued in many teceutyears; the trustees of that ttust signed key letters and docmnents 

pertaining to the statements; and the trust, as a general matter, is the legal owner of the business 

entities that constitute the assets of the Ttump Organization. See, e.g., OAGVerified Complaint 

at,I 30. 

EXHIBIT 

B 

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November 3, 2022 

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Second, 1vlr. Tromp admits he is seeking to put assets beyond· this Co1itt's reach. The 

purpo11ed suit seeks a declaration that OAG"has no jurisdictionoverthe assets of a Floridatmst.'' 

Id. (text before CountII). 

Third:, Mr. Tnllllp states he is a resident of Palm Beach, Florida. Id. ,r 1. Although OAG 

has not sought attachment here, a5 OAG,s reply papen, articulated, 011e <:frcumstance where the 

Legislature has articulated attachment is (lppropriate is when "the defeudantis auondomicifoiry 

residing without the state.'' See, e'.g., C.PL.R. 6201{1} Mr" Tmmp has thus admitted facts that 

would.suppo11 the relief of attachment-. and th11s also support the 111oremodest relief sought here. 

Fourth, the Florida suit attempts to displJte the effective service of all defendants in tlris 

action byasserting-inafootnote-thatOA.G "failedto·sue the tmstee.inhis capacity as.such/'·in 

this case. Florida Compl, fu. 1. All defertdaμts have been properly served in thisaction. See 

Certificates of Service~. NYSCEF Nos. 36 · (including certification of service 011 Donald ·Tnllllp, Jr. 

and the Trnstby service upon Donald Tnunp, Jr. 's counsel, Alan Futerfas), 120. It is baseless to 

insistthat theTmst has not been served in this case when: the Complaint is plainlyclearthat Donald 

Tmmp, Jr. is sued in both his capacity as a Tmnip Organizationexecutive{see, e~g., OAG Verified 

Complaintafif 32), as weUasthe t111stee oftheJmst(seeJ. e.g. id at ,r,r 6, 3.8, 551, 727,745,758). 

The insistence that service has not been effected (and thus no jurisdiction would purportedly exist 

over theTrnst)is only .fiuiherevidence that the inuw:diaterelief OAG seeks is necessary to prevent 

responding Defendants from evading this Courfs jurisdiction. 

Respectfully·submitted, 

Ke Wallace 

Senior Enforceme11t Collnsel 

DiVision· ofEcononlic Justice 

28 LIBERTY, NEW YORK, NY10005 • WWW.AG.NY.:GOV 

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