There were 34 counts. They're all essentially the same. Every one begins as follows:
https://www.scribd.com/document/6361000 ... from_embedAND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE,in violation of Penal Law §175.10, committed as follows:
The defendant, in the County of New York and elsewhere, on or about June 19, 2017, with intent to defraud and intent to commit another crime and aid and conceal the commission thereof...
Here's the penal code in question:
An indictment in the state of New York must contain...§ 175.10 Falsifying business records in the first degree.
A person is guilty of falsifying business records in the first degree when he commits the crime of falsifying business records in the second degree, and when his intent to defraud includes an intent to commit another crime or to aid or conceal the commission thereof.
Falsifying business records in the first degree is a class E felony.
...A plain and concise factual statement in each count which, without allegations of an evidentiary nature, (a) asserts facts supporting every element of the offense charged and the defendant's or defendants' commission thereof with sufficient precision to clearly apprise the defendant or defendants of the conduct which is the subject of the accusation...
https://casetext.com/statute/consolidat ... dictment-a
Now on to the facial validity of the indictment. It does not specify what the "another crime" is. Even if the prosecutor can prove that Trump falsified business records as alleged, that in and of itself only makes it a second degree offense (and hence a misdemeanor). To rise to the level of first degree falsification, an additional element is necessary: intent to commit another crime or conceal the commission thereof (both of which are alleged - commission and concealment). But without specifying what that "other" crime is, the indictment lacks the necessary "factual statement...which...asserts facts supporting every element...with sufficient precision to clearly apprise the defendant...of the conduct which is the subject of the accusation." The key is EVERY element. The indictment does not even state what the alleged other crime is, let alone the facts supporting it.
This SHOULD be tossed out of court in a heartbeat (even though I doubt that will happen).
That's my 2 legal cents anyways.