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39381
President said, “That’s what I want, honest loyalty. Comey said, “You will get that from
me ”182
After Comey’s account of the dinner became public, the President and his advisors disputed
that he had asked for Comey’s loyalty.183 The President also indicated that he had not invited
Comey to dinner, telling a reporter that he thought Comey had “asked for the dinner” because “he
wanted to stay on?“84 But substantial evidence corroborates Comey’s account of the dinner
invitation and the request for loyalty. The President’s Daily Diary confirms that the President
“extend[ed] a dinner invitation” to Comey on January 27.185 With respect to the substance of the
dinner conversation, Comey documented the President’s request for loyalty in a memorandum he
began drafting the night of the dinner;186 senior FBI officials recall that Comey told them about
the loyalty request shortly after the dinner occurred;187 and Comey described the request while
18' Conley 1/28/17 Memorandum, at 3; Corney 11/ 15/17 302, at 7; Hearing on Russian Election
Interference Before the Senate Select Intelligence Committee, 1 15th Cong. (June 8, 2017) (Statement for
the Record of James B. Comey, former Director of the FBI, at 4).
‘82 Comey 1/28/17 Memorandum, at 3; Corney 11/15/17 302, at 7; Hearing on Russian Election
Interference Before the Senate Select Intelligence Committee, 1 15th Cong. (June 8, 2017) (Statement for
the Record of James B. Comey, former Director of the FBI, at 4).
183 See, e.g., Michael S. Schmidt, In a Private Dinner, Trump Demanded Loyalty. Comey
Demurred., New York Times (May 1 l, 2017) (quoting Sarah Sanders as saying, “[The President] would
never even suggest the expectation of personal loyalty”); Ali Vitali, Trump Never Asked for Corney’s
Loyalty, President ’s Personal Lawyer Says, NBC (June 8, 2017) (quoting the President’s personal counsel
as saying, “The president also never told Mr. Comey, ‘I need loyalty, I expect loyalty,’ in form or
substance”); Remarks by President Trump in Press Conference, White House (June 9, 2017) (“I hardly
know the man. I’m not going to say ‘I want you to pledge allegiance.’ Who would do that? Who would
ask a man to pledge allegiance under oath?”). In a private conversation with Spicer, the President stated
that he had never asked for Comey’s loyalty, but added that if he had asked for loyalty, “Who, cares?”-
Spicer 10/16/17 302, at 4. The President also told McGahn that he never said what Corney said he had.
McGahn 12/12/17 302, at 17.
18" Interview of Donald J. Trump, NBC (May 1 l, 2017).
‘85 SCR012b_000001 (President’s Daily Diary, 1/27/17) (reflecting that the President called Comey
in the morning on January 27 and “[t]he purpose of the call was to extend a dinner invitation”). In addition,
two witnesses corroborate Comey’s account that the President reached out to schedule the dinner, without
Corney having asked for it. Priebus 10/13/ 17 302, at 17 (the President asked to schedule the January 27
dinner because he did not know much about Comey and intended to ask him whether he wanted to stay on
as FBI Director); Rybicki 1 1/21/18 302, at 3 (recalling that Comey told him about the President’s dinner
invitation on the day of the dinner).
1“ Comey 1 1/ 15/ 1 7 302, at 8; Hearing on Russian Election Interference Before the Senate Select
Intelligence Committee, 1 15th Cong. (June 8, 2017) (Statement for the Record of James B. Comey, former
Director of the FBI, 31:4).
137 McCahe 8/17/17 302, at 9-10; Rybicki 11/21/ 18 302, at 3. After leaving the White House,
Comey called Deputy Director of the FBI Andrew McCabe, summarized what he and the President had
discussed, including the President’s request for loyalty, and expressed shock over the President’s request.
McCabe 8/17/17 302, at 9. Comey also convened a meeting with his senior leadership team to discuss what
the President had asked of him during the dinner and whether he had handled the request for loyalty
properly. McCabe 8/17/17 302, at 10; Rybicki 11/21/ 18 302, at 3. In addition, Comey distributed his
n:-