!FILED: NEW YORK COUNTY CLERK 10/31/2022 06:54 PMI 

NYSCEF DOC. NO. 163 

from: 

To~ 

Cc: 

Subject: 

Date: 

Faherty Colleen 

Amy Cacfio· Lawrence Rosen 

Wallace Keyin; finketste;n Alex· Haren Enc 

People v~ The trump organization 

Wednesday, August 31, 2022 6:12:57 PM 

Hi Arny and Larry, 

INDEX NO. 452564/2022 

RECEIVED NYSCEF: 10/31/2022 

EXHIBIT 

A 

We're writing concerning the production of certain documents. After reviewing our recordsj it 

appears that TIO has not produced a full set of documents governing Mr. Trump1s revocable trust, 

including any formation documents, amendments to the trust1 or other agreements governing the 

trust's operation. The relevant production, regarding restructuring (from 3/11/22), doesn1t seem to 

have those documerits, at least not a full set. Can TTOplease produce a set of those documents by 

the end of this week? (Or, if we are mistaken, and these have been produced, we would appreciate 

your alerting us to the pertinent Bates numbers). 

Related to this issue, we have seen some indication that thetrust now is a "Florida grantor trust. 11 

See; e.g., TTO-02355681. We are unsure if any document governing the trust has changedthat 

would reflectsuch a change, but if there hasbeen such a change, piease let us know. 

We appreciate your prompt attention to these matters. Hope all else ls otherwise well. 

Best, 

Colleen 

Get Outlook far iOS 

Case 9:22-cv-81780-DMM Document 19-1 Entered on FLSD Docket 01/04/2023 Page 1 of 6
(FILED: NEW YORK COUNTY CLERK 10/31/2022 06:54 PMI 

NYSCEF DOC. NO. 164 

From: 8Uoa Hahba Es.g 

INDEX NO. 452564/2022 

RECEIVEDNYSCEF: 10/31/2022 

To: Faherty, Colleea;.wanace · Kevin; Lawrence Rosen; Amy carlin; Mlchael Madaia; Rakefstejn Alex:~ 

Ingram 

Subject: 

Date: 

Attachments: 

Good momingRe: Meet and ConferRequest 

Friday, September 16,202210:35:56 AM 

imaoe001.ona. 

I am working with the attomeys to get you yourreqnestwithout disclosing estate planning 

infonnation. 

Thank you, 

Alitia Habba, Esq. 

Habba Madaio & Associates LLP 

From: Faherty, Colleen <CoHeen.Faherty@ag.ny.gov> 

Sent: Friday, September 16, 2022 8:03:08 AM 

To: Alina Habba, Esq. <ahabba@habbalaw,com>; Wallace, Kevin <Kevin.Wallace@~g.hy~gov>; 

Lawrence Rosen <lrosen@lhrgb.com>;AmyCarlin <ACarlin@lhrgb.com>; Michael Madaio 

<mmadaio@habbalaw.com>; Finkelstein, Alex<Alex.Finkelstein@ag.ny.gov>; Randee Ingram 

<ringram@habbalaw.com> 

Subject: RE: Meet and Confer Request 

Dear Alina, et al., 

Following up on the below thread regarding the trust documents. Please confirm whether you 

intend to produce the documentsrequested. 

Additionally, we have noticed anerror With certain documents in the productions. In particular we 

have received documents that were sent password protected in their original transmission, butthat 

once prqduced to OAG,remained password protected and inaccessiblt~. (see, e,g; TTO_06198993). I 

can ask our ff folks to giv~ you a better overview ofthe documents identified; but wantto flag it for 

you in case your IT team has a quickremedy forthis. Please letme know. 

Thank you. 

Best, 

Colleen 

CoHeen K. Faherty 1.AssistanfAtforney General 

Executive Division - Federal Initiatives 

New YmkState Office of the Attorney General 

28 Liberty Street, 18th floor I New York,NY 10005 

Tel: 212.416.60461 Fax: 212.416.6009 

Case 9:22-cv-81780-DMM Document 19-1 Entered on FLSD Docket 01/04/2023 Page 2 of 6
!FILED: NEW YORK COUNTY CLERK 10/31/2022 06:54 PMI 

NYSCEF DOC. NO. 164 

INDEX NO. 452564/2022 

RECEIVED NYSCEF: 10/31/2022 

Co11een.Faherty@ag.ny.gov 

From: Faherty, Colleen 

Sent: Thursday, September 8, 2022 3:38 PM 

To: Alina Habba, Esq, <ahabba@habbalaw.com>; Wallace~ Kevin <Kevin.Wallace@ag;ny.gov>; 

Lawrence Rosen<lrosen@lhrgb.com>; Amy Carlin <ACarlin@lhrgb.com>; Michael Madaio 

<mmadaio@habbalaw.com>; Finkelstein, Alex <Alex.Finkelstein@ag;ny.gov>; Randee Ingram 

<ringram@habbalaw.com> 

Subject: RE: Meet and COnfer Request 

Alina, 

Thank you for providing this document; however, I'm afraid this dbesn'tsuffidently address our 

request because it does notget at the trust as part of the operating business enterprise that is the 

Trump Organization. The DonaldJ. Trump Revocable Trust, in general, holds the entities and 

properties that comprise the Trump Organization. As a trust, its trustee or trustees are its 

responsible officials, and a trust typically is governed bythe terms ~etby the grantor in the grantor 

otherwise later agreed to. Since thetrust's business assets have been included within the trust for 

more than five years, all documents governing the trust's operation, the responsibilities ofits 

trustees and other officials, etc., plainly are pertinent to OAG'slnvestigation. There is no basis to 

withhold any Such documents from production. 

Below is an itemized list of the excerpted trust documents we believe We have received. I can't say 

this is a c:omplete list, but these documents while relevant also do not fully address ourrequest 

because many are incomplete on their fate and we have no assurance that other agreements, 

amendments, etc., do notexist: 

• We have received an excerpted trust document, with only pages Land 46 included. 

The rest of the pages are not included. TTO _02922134. 

• We have received portions ofa second amendment tothetrust TTO_03451963. It 

does not appearwe have received the full second amendment, nor havewe 

received any firstamendment that preceded it. 

• As part of a March 11, 2022 production of a closing binder for the.late 2016/early 

2017 restructuring With numberedfiles,we received·a third amendment. 

TTO_05698935. Wedo not know ifthere were subsequentamendments. 

• As part of that same closing-binder production, we received a document appearing 

to be a set of trust instructions. TTO...:..05698019. We do notknow if this is the only 

set of instructions, or if there are later.sets of instructions or qther arrangements or 

agreements that would govern operation of the trust. 

We appreciate your working With us, but are constrained to restate our request for the documents 

establishing the Donald J. Trump Revocable Trust dated April 7, 2014, any amendments thereto, and 

any document reflecting a change in the status of that Trustto "a Florida grantortrust". For the 

avoidance of doubt, the request includes any formation documents, amendments tothe trust, or 

Case 9:22-cv-81780-DMM Document 19-1 Entered on FLSD Docket 01/04/2023 Page 3 of 6
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NYSCEF DOC. NO. 164 

INDEX NO. 452564/2022 

RECEIVED NYSCEF: 10/31/2022 

other documents governing the trust's operation. We do hot understand how a production ofthis 

set of documents could be difficult or time.:.consuming. We ask for production by the end of this 

week. 

Thank you. 

Best, 

Colleen 

Colleen K. Faherty I Assistant Attorney General 

Executive Division-Federalirlitiatives 

New York State Office of the Attorney General 

28 Liberty Street. 18th floor! New York, NY 10005 

Tel: 212.416.6046 l Fax: 212.416.6009 

Colleen.Faherty@ag.ny.eov 

From: Alina Habba, Esq'.<ahabba@habbalaw.com> 

Sent: Wednesdayi September 7,2022 3:44 PM 

To: Faherty/ Colleen <Collerm Fahertv@ag DY f;OV>; Wallace, Kevin <Kevin Wa!lace(wag.ny,gov>; 

Lawrence Rosen <!rosen@lhrgb.com>; Amy Carlin <ACarlin@lhrgb;eotn>; Michael Madaid 

<rnmadaio(@habba!aw.corn>; Finkelstein, Alex <Alex.Finkelstein{@ag.nv;gov>; Randee Ingram 

<ringramffiJhabbalaw com> 

Subject: RE: Meet and Confer Request 

Hi Colleen, 

In response to your request I am able to provide two confidential documents ln addition to those 

that TIO had in their possession and previously produced to the OAG~ As per my call with Kevin and 

Colleen yesterday, I believe these documents should include all information the OAG is seeking or 

would require, as is relevanttothis investigation, Without divulging anyofthe highly-Sensitive estate 

planning information which we would obviously object to. 

Please let.me know if I can be of any further assistance. 

Very truly yours, 

Alina Habba, Esq. 

Habba Madaio & Associates LLP 

Case 9:22-cv-81780-DMM Document 19-1 Entered on FLSD Docket 01/04/2023 Page 4 of 6
[FILED: NEW YORK COUNTY CLERK 10/31/2022 06:54 PMI 

NYSCEF DOC. NO. 164 

ALINA HABBA, EsQ. 

Admitted to Practice In NJ, NY & CT 

HABBA MADAIO 

1430 US Highway 206, Suite 2.40 

Bedminster, New Jersey 07921 

Telephone: 908-869-1188 

Facsimile: 908-450-1881 

INDEX NO. 452564/2022 

RECEIVED NYSCEF: 10/31/2022 

TI1e information in this e-mail is confidential and may be legally privileged. ffyou are not the intended recipie.iit, you 

must not read, use o.r disseminate the info.anatio11 . .Althcmgh this e..;mail and any attachments ate believed to be free of 

any · virus or other defect that might affect ,any computer system into which it is received and opened~· it is the 

responsibility of the recipient· to · ensw:e that it is virus free and no responsibility is accepted by Habba Madaio & 

Associates LLP for any loss .or damage arising in anyway from its use. 

From: Faherty, Colleen <Colleen faberty(@agny gov> 

Sent:Thursday,September 1; 20221:45 PM 

To: AlinaHabba,Esq. <ahabba@habbalaw.com>; Wallace, KeVin <Kevin.Wallace@aitny.gov>; 

Lawrence Rosen <lrosen6iJ!hrgb.corn>; Amy Carlin <ACadin@Hhrgb;eom>; Michael Madaio 

<mmadajo@babbalaw com>;Hnkelstein, Alex <Alex fiokelstein@a~ ny ~ov>; Peter Gabra 

<pgabra@babbalaw com>; Randee Ingram <ringrarn@habbalaw mm> 

Subject: RE: Meet and Confer Request 

Hi Alina~ 

Given the extensive litigation over productions to date, we think itis best to communicate in writing, 

so please consider this email our meet and confer; 

The request is for the documents establishing the Donald J. Trump Revocable Trust dated April 7, 

2014 and any documentreflecting a change in the status of thatTrustto .. ,a Floridcl grantor trust' as 

shown in the attached document. For the avoidance of doubt, the request includes any formation 

documents, amendments tQ the trust, or other documents governingthe trust's operation. We 

expect these documents will be straightforward to obtain and produce. 

As the Trust holds all of the assets valued in the SOFt's and its Trustees are responsible for the 

presentation of the statements from 2016fqrward,these arebasic,foundational documents, but we 

have not been able to identify them (or complete versions of them} in the productions to date. If 

TTO can identify the relevant hates numbers,.great. If not;We would likethem produced ASAP~ If you 

decline, we would like to know ASAP. (But we Will add that these documents are properly called for 

Case 9:22-cv-81780-DMM Document 19-1 Entered on FLSD Docket 01/04/2023 Page 5 of 6
(FILED: NEW YORK COUNTY CLERK 10/31/2022 06:54 PMI 

NYSCEF DOC. NO. 164 

by a number of subpoenas:) 

Much appreciated. 

Best, 

Colleen 

CoUeen K. Faherty l AssistantAttorney General 

Executive Division - Federal Initiatives 

New York State Office of th~ Attorney General 

28 Liberty Streett 18th floor I NewYork~ NY 10005 

Tel: 212.416.6046 J Fax: 212.416.6009 

Cnlls"f'JJ Faherty@ag nygnv 

From: Alina Habba, Esq. <ahabba@babbalawcom> 

Sent: Thursday, September 1, 202212:17 PM 

INDEX NO. 452564/2022 

RECEIVED NYSCEF: 10/31/2022 

To: Faherty, Colleen <Col!een.Faherty(@ag.ny.gov>; WaUate, Kevin <Kevin. Wallace(ruag,ny~gov>; 

Lawrence Rosen <lrosen@lhrgbcam>; Amy Carlin <ACadjn@lbrgb com>; Mkhc1el Madaio 

<rnmadaio(whabbalaw com>; Finkelstein, Alex <Alex Finkelstein@a~ ny eov>; Peter Gabra 

<pgabra@habbalaw.com>; Randee Ingram <iingram(@habbalaw .corn> 

Subject: Meet and Confer Request 

Good morning, 

I understand a request was made for additional documents yesterday regarding the trust. Please 

provide me with some times thatwor~ toniorrowfora meet and confer so I can assist with this and 

take a look at what has been provided historically by TIO for you. 

Thank youi 

Alina Habba, Esq. 

Habba Madaio &. Associates LLP 

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Case 9:22-cv-81780-DMM Document 19-1 Entered on FLSD Docket 01/04/2023 Page 6 of 6