Page:2019-12-02-report-of-evidence-in-the-democrats-impeachment-inquiry-in-the-house-of-representatives.pdf/65

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A. I am not.

Q. Okay. So the idea of a quid pro quo is it's a concept where there is a demand for an action or an attempt to influence action in exchange for something else. And in this case, when people are talking about a quid pro quo, that something else is military aid. So, if nobody in the Ukrainian government is aware of a military hold at the time of the Trump-Zelensky call, then, as a matter of law and as a matter of fact, there can be no quid pro quo based on military aid. I just want to be real clear that, again, as of July 25th, you have no knowledge of a quid pro quo involving military aid.

A. July 25th is a week after the hold was put on the security assistance. And July 25th, they had a conversation between the two presidents where it was not discussed.

Q. And to your knowledge, nobody in the Ukrainian government was aware of the hold?

A. That is correct.[1]

Likewise, Philip Reeker, the Acting Assistant Secretary of State for Europeans Affairs, testified that he was unaware of any U.S. official conveying to a Ukrainian official that President Trump sought political investigations.[2] Acting Assistant Secretary Reeker testified that he was not aware of whether Ambassador Volker or Ambassador Sondland had such conversations with the Ukrainians.[3]

Some witnesses testified that the Ukrainian embassy made informal inquiries about the status of the security assistance. LTC Vindman recalled receiving "light queries" from his Ukrainian embassy counterparts about the aid in either early- or mid-August, but he was unable to pinpoint specific dates, or even the week, that he had such conversations.[4] LTC Vindman testified that Ukrainian questions about the delay were not "substantive" or "definitive" until around the time of the Warsaw summit, on September 1.[5] State Department official Catherine Croft testified that two individuals from the Ukrainian embassy approached her about a pause on security assistance at some point before August 28, but Croft told them she "was confident that any issues in process would get resolved."[6] Deputy Assistant Secretary of Defense Laura Cooper testified publicly that her staff received inquiries from the Ukrainian embassy in July that "there was some kind of issue" with the security assistance; however, she did not know what the Ukrainian government knew at the time.[7]


  1. Taylor deposition, supra note 47, at 119-20.
  2. Deposition of Philip Reeker in Wash., D.C., at 149 (Oct. 26, 2019).
  3. 315Id. at 150.
  4. Vindman deposition, supra note 12, at 135-37, 189-90.
  5. Id. at 189-90.
  6. Croft deposition, supra note 60, at 86-87.
  7. Impeachment Inquiry: Ms. Laura Cooper and Mr. David Hale, supra note 246.

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