Page:2019-12-02-report-of-evidence-in-the-democrats-impeachment-inquiry-in-the-house-of-representatives.pdf/81

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month that President Trump was elected.[1] In the week after election night, FBI Agent Peter Strzok and FBI lawyer Lisa Page—who were both involved in the Russia collusion investigation—wrote to each other: "OMG THIS IS F*CKING TERRIFYING" and "I bought all the president's men. Figure I needed to brush up on watergate [sic]."[2]

The FBI surveilled Trump campaign associates using evidence delivered by Christopher Steele—a confidential human source funded by then-candidate Trump's political opponents and who admitted he was "desperate" that Donald Trump lose the election.[3] During her deposition, Dr. Hill testified that Steele's reporting was likely a bogus Russia misinformation campaign against Steele.[4] Yet, the FBI accepted Steele's information and used it to obtain surveillance warrants on Trump campaign associate Carter Page.[5] Ultimately, Special Counsel Mueller's report concluded that the Trump campaign did not conspire or coordinate with Russian election interference actions.[6] In considering the President's mindset, this context cannot be ignored.

3. The President has the constitutional authority to remove Ambassador Yovanovitch.

U.S. ambassadors are the President's representatives abroad, serving at the pleasure of the President. Every ambassador interviewed during this impeachment inquiry recognized and appreciated this fact.[7] Even Ambassador Yovanovitch understood that the President could remove any ambassador at any time for any reason, although she unsurprisingly disagreed with the reason for her removal.[8] The removal of Ambassador Yovanovitch, therefore, is not per se evidence of wrongdoing for the President's political benefit. Evidence suggests that President Trump likely had concerns about Ambassador Yovanovitch's ability to represent him in Ukraine,[9] and that then-Ukrainian President


  1. Inspector Gen., Dep't of Justice, A Review of Various Actions by the Federal Bureau of Investigation and Department of Justice in Advance of the 2016 Election, 396, 419 (2018).
  2. Id. at 397, 400.
  3. F.B.I., Dep't of Just., 302 Interview with Bruce Ohr on Dec. 19, 2016 at 3.
  4. See Hill deposition, supra note 12, at 177-180 ("I think it was a rabbit hole . . . . The way that the Russians operate is that they will use whatever conduit they can to put out information that is both real and credible but that also masks a great deal of disinformation . . . .").
  5. Transcribed Interview of Sally Moyer, in Wash., D.C., at 162 (Oct. 23, 2018).
  6. Mueller report, supra note 416.
  7. Sondland deposition, supra note 51, at 19; Volker transcribed interview, supra note 60, at 88-89; Transcribed interview of Ambassador Michael McKinley, in Wash., D.C., at 37 (Oct. 16, 2019) [hereinafter "McKinley transcribed interview"]; Yovanovitch deposition, supra note 115, at 23; Taylor deposition, supra note 47, at 297; Hale deposition, supra note 230, at 38.
  8. Yovanovitch deposition, supra note 115, at 23. Evidence suggests that Ambassador Yovanovitch took steps to gain the President's trust. Deputy Assistant Secretary of State George Kent testified that Ambassador Yovanovitch taped videos in which she proclaimed support for the Trump Administration's foreign policies. Kent deposition, supra note 65, at 118-19. Ambassador Yovanovitch testified that she sought Ambassador Sondland's guidance on how to address negative news reports critical of her work as Ambassador to Ukraine. She said that Ambassador Sondland told her to "go big or go home" in publicly supporting the President. Yovanovitch deposition, supra note 115, at 267-28, 306-07. Ambassador Sondland, however, testified that he did not recall advising Ambassador Yovanovitch to make a public statement. Sondland deposition, supra note 51, at 58-59.
  9. Memorandum of Telephone Conversation, supra note 15.

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