Good point. That one is easy:

Failure to state an offence

Regardless of any evidence, facts, legal opinions or theory, counts 31 -37 are barred by statutory exception or immunity under the provisions and exemptions in the Former Presidents Act—Public Law 85-745 (3 U.S.C. § 102 note) (b), the Presidential Records Act, 18 USC § 2205(3), 18 USC §2203(f), and 18 USC §2203(g)(1), and relevant case law, See Judicial Watch, Inc. v. Nat’l Archives & Records Admin., 845 F. Supp. 2d 288 (D.D.C. 2012) and Department of the Navy v. Egan, 484 U.S. 518 (1988), and therefore insufficient to bring cause of action.