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its impeachment against him for high crimes and mis-
demeanors. 
ARTICLE I 
In his conduct of the office of President of the United 
States—in violation of his constitutional oath to faithfully 
execute the office of President of the United States and, 
to the best of his ability, preserve, protect, and defend the 
Constitution of the United States, and in violation of his 
constitutional duty to take care that the laws be faithfully 
executed—Donald J. Trump has abused the powers of the 
Presidency in an attempt to circumvent and subvert the 
rule of law by inciting an insurrection against the Govern-
ment of the United States of America, in that: 
In a pattern of conduct attempting to create an insur-
rection against the Government of the United States, Don-
ald J. Trump spread disinformation and allegations un-
supported by any evidence regarding voter fraud in the 
2020 United States Presidential election and the results 
of the 2020 United States Presidential election, and ex-
plicitly encouraged his supporters to descend on Wash-
ington, DC, on January 6, 2021, while Congress engaged 
in its constitutionally mandated legislative business of cer-
tifying the electoral college results of the 2020 United 
States Presidential election. 
Prior to January 6, 2021, Donald J. Trump told 
white supremacists to ‘‘stand back and stand by’’, an ap-
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peal to white supremacy consistent with his prior remarks 
and conduct, including an August 31, 2020, statement in 
defense of an extremist charged with murdering peaceful 
protestors and an August 15, 2017, statement defending 
white supremacists who had committed violence in Char-
lottesville, Virginia, as ‘‘very fine people’’. On December 
20, 2020, Donald J. Trump stated that the January 6, 
2021, show of force he purposefully incited would be 
‘‘wild’’. 
On January 6, 2021, Donald J. Trump explicitly told 
his supporters to ‘‘fight like hell’’, and ‘‘you’ll never take 
back our country with weakness. You have to show 
strength.’’. Shortly thereafter, those same supporters en-
gaged in mass riots and insurrection on the grounds of 
the United States Capitol, leading to the breach and de-
struction of the Capitol building while Congress was in 
session conducting legislative business, as well as the 
death of at least five individuals, including a Capitol Police 
officer. The siege of the United States Capitol at the 
hands of Donald J. Trump created widespread terror, 
threatened the lives of members of the United States Con-
gress, completely disrupted legislative business, threatened 
the continuity of government, and exposed the United 
States to grave national security risks. 
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In all of this, Donald J. Trump has undermined the 
integrity of his office, has betrayed his trust as President, 
has acted in a manner which threatens the integrity and 
security of the United States Government and its people, 
has subverted the Constitution of the United States, the 
democratic process, and the rule of law and justice, has 
conspired to commit sedition and incited an insurrection 
against the United States Government, and has behaved 
in a manner grossly incompatible with the office of the 
President of the United States to the manifest injury of 
the people of the United States. 
Wherefore, Donald J. Trump, by such conduct, war-
rants impeachment and trial, and removal from office and 
disqualification to hold and enjoy any office of honor, 
trust, or profit under the United States. 
ARTICLE II 
In his conduct of the office of President of the United 
States—in violation of his constitutional oath to faithfully 
execute the office of President of the United States and, 
to the best of his ability, preserve, protect, and defend the 
Constitution of the United States, and in violation of his 
constitutional duty to take care that the laws be faithfully 
executed—Donald J. Trump has abused the powers of the 
Presidency in an attempt to circumvent and subvert the 
rule of law by corrupting the electoral process, in that: 
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In a pattern of conduct dedicated to corrupting the 
electoral process, Donald J. Trump solicited a foreign gov-
ernment, Ukraine, to intervene in the 2020 United States 
Presidential election by requesting that the Government 
of Ukraine publicly announce baseless investigations into 
his political rival to the benefit of his potential reelection. 
Donald J. Trump sought to ensure such investigations by 
conditioning United States Government support and acts 
of value on the acquiescence of the Government of Ukraine 
to Donald J. Trump’s demands. In so doing, Donald J. 
Trump abused the power of the Presidency by subverting 
the rule of law in a manner that undermined national se-
curity and violated his duties to preserve, protect, and de-
fend the Constitution. 
Following the results of the 2020 United States Pres-
idential election, in a January 2, 2021, discussion between 
Donald J. Trump and Georgia State officials, Donald J. 
Trump solicited the assistance of the Georgia Secretary 
of State in overturning the free and fair election results 
in the State of Georgia, stating that ‘‘I just want to find 
11,780 votes, which is one more than we have’’. When the 
Georgia Secretary of State did not agree to his demands, 
Donald J. Trump threatened the Georgia officials with 
criminal prosecution if they didn’t comply, stating that 
leaving the vote counts intact would be a ‘‘big risk’’. 
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Further, during the 2016 United States Presidential 
election, Donald J. Trump approved and directed a sur-
reptitious and unlawful payment of substantial sums of 
money to obtain the silence of persons with unfavorable 
information about him in order to influence the 2016 
United States Presidential election. 
In all of this, Donald J. Trump has undermined the 
integrity of his office, has betrayed his trust as President, 
has acted in a manner which threatens the integrity and 
security of the United States Government and its people, 
has subverted the Constitution of the United States, the 
democratic process, and the rule of law and justice, has 
purposefully and maliciously corrupted public faith and 
trust in the electoral process, and has behaved in a man-
ner grossly incompatible with the office of the President 
of the United States to the manifest injury of the people 
of the United States. 
Wherefore, Donald J. Trump, by such conduct, war-
rants impeachment and trial, and removal from office and 
disqualification to hold and enjoy any office of honor, 
trust, or profit under the United States. 
ARTICLE III 
In his conduct of the office of President of the United 
States, Donald J. Trump, in violation of his constitutional 
oath faithfully to execute the office of President of the 
United States and, to the best of his ability, preserve, pro-
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tect, and defend the Constitution of the United States, 
and in violation of article I, section 9, clause 8 and article 
II, section 1, clause 7 of the Constitution, has accepted 
emoluments from foreign states without the consent of 
Congress and has received and accepted emoluments from 
the United States and from individual States, and in doing 
so, Donald J. Trump has run afoul of anticorruption pro-
visions of the United States Constitution, in that: 
In attempts to leverage the office of the President 
of the United States for personal profit, Donald J. Trump 
solicited and received from foreign governments presents 
and emoluments, designed to curry favor and to influence 
him. To facilitate his receipt of emoluments from foreign 
states, Donald J. Trump has failed to divest his ownership 
stakes in, or meaningfully separate himself from, the 
Trump Organization’s vast network of business holdings, 
which engage with foreign governments. Through those 
business holdings, Donald J. Trump has received, and 
continues to receive, presents and emoluments, either di-
rectly or indirectly, from foreign governments. His receipt 
of presents and emoluments from foreign states creates 
both a conflict of interest between his personal business 
interests and his responsibilities as President of the 
United States, and an appearance that he is beholden to 
the foreign states from which he received the emoluments. 
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Donald J. Trump has failed to disclose to Congress, 
or the public, the full extent of the presents or emoluments 
he has received from foreign states through his business 
interests, thereby violating his constitutional responsibility 
to obtain congressional consent to obtain such emoluments 
as required by article I, section 9, clause 8. 
Further, Donald J. Trump’s receipt of emoluments 
and additional payments—including from lease agree-
ments, other rental property agreements such as that with 
the General Services Administration for the Trump Inter-
national Hotel in Washington, DC, and payments from 
Federal agencies such as the United States Secret Serv-
ice—from the United States and from individual States 
beyond his salary directly violates article II, section 1, 
clause 7 of the United States Constitution, which prohibits 
the President from receiving benefits, monetary or other-
wise, from the Federal Government, State governments, 
local governments, or their instrumentalities beyond the 
fixed Presidential compensation. 
In all of this, Donald J. Trump has used the power 
of his office for improper personal gain, has abused and 
exceeded the lawful powers of his office, has undermined 
the integrity of his office, has betrayed his trust as Presi-
dent, and has behaved in a manner grossly incompatible 
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with the office of the President of the United States to 
the manifest injury of the people of the United States. 
Wherefore, Donald J. Trump, by such conduct, war-
rants impeachment and trial, and removal from office and 
disqualification to hold and enjoy any office of honor, 
trust, or profit under the United States. 
ARTICLE IV 
In his conduct of the office of President of the United 
States—in violation of his constitutional oath to faithfully 
execute the office of President of the United States and, 
to the best of his ability, preserve, protect, and defend the 
Constitution of the United States, and in violation of his 
constitutional duty to take care that the laws be faithfully 
executed—Donald J. Trump has prevented, obstructed, 
and impeded the administration of justice, in that: 
In a pattern of conduct solely dedicated to the ob-
struction of the administration of justice, on June 17, 
2017, Donald J. Trump directed the firing of Special 
Counsel Robert S. Mueller, III, who was investigating co-
ordination between the 2016 Donald J. Trump United 
States Presidential campaign and the Russian Govern-
ment, and in early 2018, Donald J. Trump ordered Fed-
eral officials to lie about this June 17, 2017, directive. 
Donald J. Trump further directed or compelled agencies, 
personnel, and former personnel of the executive branch 
to refuse to comply with lawful congressional requests for 
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information and testimony, and otherwise suppressed co-
operation with congressional inquiries. 
In all of this, Donald J. Trump has undermined the 
integrity of his office, has betrayed his trust as President, 
has acted in a manner which threatens the integrity and 
security of the United States Government and its people, 
has subverted the Constitution of the United States, the 
democratic process, and the rule of law and justice, and 
has behaved in a manner grossly incompatible with the 
office of the President of the United States to the manifest 
injury of the people of the United States. 
Wherefore, Donald J. Trump, by such conduct, war-
rants impeachment and trial, and removal from office and 
disqualification to hold and enjoy any office of honor, 
trust, or profit under the United States. 
Æ 
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