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and for the people, has acted in a manner grossly incom-
patible with self-governance and the rule of law, and will 
remain a threat to the Constitution if allowed to remain 
in office. 
ARTICLE V: CREATION OF UNLAWFUL OFFICE 
The Constitution provides that the House of Rep-
resentatives ‘‘shall have the sole Power of Impeachment’’ 
and that the President ‘‘shall be removed from Office on 
Impeachment for, and Conviction of, Treason, Bribery, or 
other high Crimes and Misdemeanors’’. Further, Section 
2 of Article II of the Constitution states that the President 
‘‘shall appoint Ambassadors, other public Ministers and 
Consuls, Judges of the supreme Court, and all other Offi-
cers of the United States . . . but the Congress may by 
Law vest the Appointment of such inferior Officers, as 
they think proper, in the President alone, in the Courts 
of Law, or in the Heads of Departments’’. In his conduct 
of the office of President of the United States—and in 
violation of his constitutional oath to faithfully to execute 
the office of President of the United States and, to the 
best of his ability, preserve, protect, and defend the Con-
stitution of the United States, and in violation of his con-
stitutional duty to take care that the laws be faithfully 
executed—Donald John Trump has abused the powers of 
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the Presidency in a manner offensive to, and subversive 
of, the Constitution, in that: 
Using the powers of his high office, Donald John 
Trump has, through unlawful orders and directives, cre-
ated an unlawful office, the so-called Department of Gov-
ernment Efficiency (‘‘DOGE’’), and assigned an extensive 
range of unlawful powers, effectively granting this fla-
grantly unconstitutional creation significant control over 
the executive branch. Donald John Trump has appointed 
Mr. Elon Musk as the de facto head of this contrived enti-
ty, which was not created or funded by any law, without 
a formal title or office. These actions have been in direct 
violation of the Constitution’s requirement that principal 
officers of the United States must be created by law and 
their appointees confirmed by the Senate, and that inferior 
offices must be created by law with their appointment 
vested as Congress may determine. 
Additionally, he has vested these powers in Mr. Musk 
without complying with the constitutional requirement 
that all officers of the United States be commissioned by 
the President and swear an oath of office to support the 
Constitution. Mr. Musk has been designated as a special 
government employee of the White House Office, in viola-
tion of statutory authorization and restrictions on such 
designations. This false claim has also been used to com-
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mit violations of the ethics, disclosure, and conflict-of-in-
terest laws applicable to government officers and regular 
employees. 
Contrary to the Government’s claims in court, Mr. 
Musk has exercised de facto control over DOGE and, 
through it, control over a wide range of Government de-
partments and agencies. This unmistakable reality has 
been repeatedly and openly stated by the Trump Adminis-
tration, including by Donald John Trump’s own address 
to Congress on March 4, 2025. In this capacity, Mr. Musk 
and his subordinates have undertaken numerous violations 
of the Constitution and laws, including by— 
(1) impoundment of funds appropriated by 
Congress; 
(2) violations of privacy and security laws with 
respect to sensitive information systems, personally 
identifiable information, and classified material; and 
(3) termination of government employees under 
false pretenses and in violation of civil service laws. 
These actions have vastly exceeded the terms of the 
formal executive orders purporting to create DOGE under 
the direction of a ‘‘U.S. DOGE Service Administrator’’, 
an office which remained vacant for several weeks, with 
the Government’s own attorneys claiming in court that the 
official head of DOGE was unknown to them. Since that 
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time, a nominal Administrator has been named, despite 
the repeated avowals from the President and his Adminis-
tration that Mr. Musk controls and directs DOGE, as con-
firmed by ample public reporting and Mr. Musk’s own 
statements. 
Donald John Trump has abused the powers of his 
high office and breached the public trust by establishing 
the so-called Department of Government Efficiency and 
unconstitutionally placing Mr. Musk in control of this enti-
ty, knowingly provided false testimony to the court regard-
ing the leadership of the said entity, and directing the un-
lawful entity to implement his agenda, in violation of the 
Constitution’s objective of establishing Justice and funda-
mental rules for how the executive branch of the United 
States is to be structured and how persons may be ap-
pointed to public office. 
Wherefore, Donald John Trump, by such conduct, 
has demonstrated that he is unfit to govern a Nation by 
and for the people, has acted in a manner grossly incom-
patible with self-governance and the rule of law, and will 
remain a threat to the Constitution if allowed to remain 
in office. 
ARTICLE VI: BRIBERY AND CORRUPTION 
The Constitution provides that the House of Rep-
resentatives ‘‘shall have the sole Power of Impeachment’’ 
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and that the President ‘‘shall be removed from Office on 
Impeachment for, and Conviction of, Treason, Bribery, or 
other high Crimes and Misdemeanors’’. Further, Section 
9 of Article I of the Constitution states that ‘‘no Person 
holding any Office of Profit or Trust under them, shall, 
without the Consent of the Congress, accept of any 
present, Emolument, Office, or Title, of any kind what-
ever, from any . . . foreign State’’. In his conduct of the 
office of President of the United States—and in violation 
of his constitutional oath to faithfully to 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 John Trump has abused the powers of the Presi-
dency in a manner offensive to, and subversive of, the Con-
stitution, in that: 
Donald John Trump has engaged in a pattern of un-
lawful corruption for the personal profit of himself and 
his associates, soliciting and accepting bribes in exchange 
for official actions, policy influence, and favorable treat-
ment from the Administration. In so doing, he has, beyond 
a reasonable doubt, profiteered from public office on a 
scale unprecedented in American history. 
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Donald John Trump has engaged in fraudulent con 
artist schemes through ‘‘pump and dump’’ or ‘‘rug pull’’ 
tactics for cryptocurrency tokens he has created, and at 
the same time, enabled a direct conduit for bribes paid 
to him in exchange for official actions. 
Donald John Trump has also leveraged the threat of 
hostile government action and the corresponding offer of 
preferential treatment in order to extract large payments 
in the form of settlements for meritless and vexatious liti-
gation he pursues in his personal capacity, thereby cor-
rupting both the executive branch and the judiciary. To 
advance this end, Donald John Trump solicited and re-
ceived $940,000,000 in pro bono services from prominent 
law firms to help causes he personally supports. 
Donald John Trump has refused to divest himself or 
take any steps to prevent conflicts of interest in his sub-
stantial personal business ventures, creating another con-
duit for the payment of bribes. 
Donald John Trump has permitted and encouraged 
his subordinates to violate laws regarding ethics, disclo-
sures, and self-dealing, and through these actions, he has 
enabled and encouraged corruption and graft by his rel-
atives, associates, and political allies. 
Donald John Trump has, in these ways and others, 
solicited payments from foreign governments for corrupt 
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purposes and in flagrant violation of the Constitution’s 
prohibition on foreign emoluments. 
Wherefore, Donald John Trump, by such conduct, 
has demonstrated that he is unfit to govern a Nation by 
and for the people, has acted in a manner grossly incom-
patible with self-governance and the rule of law, and will 
remain a threat to the Constitution if allowed to remain 
in office. 
ARTICLE VII: TYRANNY 
The Constitution provides that the House of Rep-
resentatives ‘‘shall have the sole Power of Impeachment’’ 
and that the President ‘‘shall be removed from Office on 
Impeachment for, and Conviction of, Treason, Bribery, or 
other high Crimes and Misdemeanors’’. Further, the sys-
tem of checks and balances, as well as the separation of 
powers, as defined in the Constitution, work to ensure that 
the Office of the President does not become tyrannical. 
In his conduct of the office of President of the United 
States—and in violation of his constitutional oath to faith-
fully to 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 faith-
fully executed—Donald John Trump has abused the pow-
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ers of the Presidency in a manner offensive to, and subver-
sive of, the Constitution, in that: 
He has, by his actions and statements, sought to es-
tablish himself as tyrant, dictator, and autocrat over the 
People of the United States, usurping unto himself the 
constitutional powers of Congress, the courts, and the 
States, and powers illegitimate and beyond the scope of 
lawful government altogether. 
He has claimed for himself absolute and arbitrary 
power, the ability to suspend laws at whim, and utterly 
disregarded and betrayed his oath to faithfully execute the 
office of President of the United States and to preserve, 
protect, and defend the Constitution of the United States. 
He has denied and violated the right of the People 
of the United States to freedom of speech, and of assem-
bly, and to petition the government for redress of griev-
ances. 
He has denied and violated the right of the People 
of the United States to due process of law and equal pro-
tection under the laws, to fair and impartial independent 
courts, and to legal counsel. 
He has sought to intimidate and coerce, by means 
including the threat of unlawful prosecutions and by en-
couraging violence and threats of violence, the Representa-
tives and Senators in Congress. 
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He has denied and violated the separation of powers 
and the Constitution’s system of checks and balances, ar-
rogating unto himself the legislative and judicial powers, 
including the power of Congress to levy taxes, appropriate 
public funds, direct the organization of officers and agen-
cies of the executive branch, and to make laws. 
He has sought to intimidate, coerce, and extort the 
officers of the several States, including those elected by 
the People thereof, and thereby sought to commandeer the 
several States, in violation of their sovereignty and the 
system of federalism established by the Constitution of the 
United States. 
He has sought to abrogate the citizenship clause of 
the 14th Amendment to the Constitution, by means in-
cluding the issuance of an executive order that directs ex-
ecutive departments and agencies to withhold citizenship 
from certain classes of persons who are born within the 
United States. 
He has repeatedly threatened and suggested that he 
intends to violate the Presidential term limits established 
by the 22d Amendment to the Constitution, and adopted 
overtly monarchical aspirations and affectations, including 
by invoking and endorsing theories that he is above the 
law or that his personal will constitutes the law. 
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In all of this, Donald John Trump has willfully dis-
regarded Federal laws and the Constitution, imperiled a 
coequal branch of Government, and threatened the integ-
rity of the democratic system. He thereby betrayed his 
trust as President, abused the powers of the Presidency, 
acted in a manner grossly incompatible with self-govern-
ance and the rule of law, and has committed High Crimes 
and Misdemeanors in attempting to establish himself as 
a lawless tyrant to the manifest injury of the people of 
the United States. 
Wherefore, Donald John Trump, by such conduct, 
has demonstrated that he is unfit to govern a Nation by 
and for the people, has acted in a manner grossly incom-
patible with self-governance and the rule of law, and will 
remain a threat to the Constitution if allowed to remain 
in office. 
Æ 
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