(FILES) (COMBO) This combination of pictures created on August 5, 2023 shows special counsel Jack Smith in Washington, DC, on August 1, 2023 and former US President Donald Trump in Palm Beach, Florida, on November 8, 2022. Donald Trump launched a "private criminal effort" to subvert the 2020 US election and should not be shielded by presidential immunity, Special Counsel Jack Smith said in a court filing unsealed on October 2, 2024. Smith, in a 165-page motion arguing for the historic case against Trump to move forward, also provided new evidence of the former president's efforts to overturn the results of the election won by Democrat Joe Biden. (Photo by SAUL LOEB and Eva Marie UZCATEGUI / AFP) (Photo by SAUL LOEBEVA MARIE UZCATEGUI/AFP via Getty Images)