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In his conduct of the office of President of the United States, Donald J. Trump, in violation of his constitutional duty to preserve, protect, and defend the Constitution of the United States, and to take care that the laws be faithfully executed, has refused to spend funds appropriated by Congress, has expended funds not appropriated by Congress, has diverted funds specifically earmarked for one purpose to advance a contrary purpose, and has used private funds for a Government purpose, for example, a White House ballroom, unlawfully to circumvent the congressional power of the purpose enshrined in article I, section 9, clause 7 of the Constitution, the Impoundment Control Act, and the Anti-Deficiency Act, among other things.