Also from the Just Security article:
In terms of part (2), intent to defraud, “courts in the First Department have interpreted this culpable mental state broadly. Intent to defraud is not constricted to an intent to deprive another of property or money. In fact, ‘intent to defraud’ can extend beyond economic concern. Nor is there any requirement that a defendant intend to conceal the commission of his own crime; instead, ‘a person can commit First Degree Falsifying Business Records by falsifying records with the intent to cover up a crime committed by somebody else.’” People v. Trump 2024 NY Slip Op 30560(U). Note that the state’s pattern jury instructions say that intent “means conscious objective or purpose. Thus, a person acts with intent to defraud when his or her conscious objective or purpose is to do so.”
Did you happen to mention Michael Cohen? 