DA Alvin Bragg’s indictment accuses the defendant [former President Donald Trump (R)] of the crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE in thirty-four counts.

Thirty-four counts of made and caused a false entry in the business records of an enterprise…, all of them centered on voucher entries into a Detail General Ledger, and check stubs and invoices kept…somewhere.

Thirty-four counts of intent to defraud and intent to commit another crime and aid and conceal the commission thereof…. leading into the sentences claiming those false entries. But nowhere does Bragg say who he thinks was the target of the “defraud,” nor does he say what that “another crime” is. Absent a defraud victim, there is no defrauding. By withholding what that other crime is, Bragg is denying the defendant his opportunity—his right—to answer the charge of that other crime.

False entries. Maybe—maybe—three real counts, but cut apart and expanded in 34 of them.

Withholding what that “another crime,” though, 34 times…. How about: false indictment.

Bragg’s charging document, the output of his grand jury, can be read here.