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Harm to Ongoing Matter “Main idea: Use any opportunit to criticize Hillar Clinton and the rest exce t Sanders

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., New York Times (May 1 l, 2017) (quoting Sarah Sanders as saying, “[The President] would never even

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House to discuss whether the President should visit FBI headquarters and make a speech to 467 See, ag, Sarah

Sanders, White House Daily Briefing, C-SPAN (May 10, 2017); SCR013_0010~88 (5/10/17 Email, Hemming to

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for in the 2016 presidential election.477 In the afiemoon of May 10, 2017, deputy press secretary Sarah

See SC_AD_00347 (Donaldson 5/10/17 Notes). ' 478 Sanders 7/3/18 302, at 4; Sarah Sanders, White House

Daily Briefing, C-SPAN (May 10, 2017). 479 Sarah Sanders, White House Daily Briefing, C-SPAN (May 10,

2017‘); Sanders 7/3/18 302, at 4. 430 Sarah Sanders, White House Daily Briefing, C-SPAN (May 10, 2017)

. 48‘ Sanders 7/3/ 18 302, at 4. 432 Sanders 7/3/18 302, at 4

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“ On June 13, 2017, Sanders asked the President for guidance on how to respond to press inquiries about

the possible firing of the Special Counsel.555 The President dictated an answer, which Sanders delivered

Firing Mueller as Special Counsel, New York Times (June 12, 2017). 55“ Ruddy 6/6/18 302, at 6-7. 5‘55 Sanders

al., Trump Stews, Staff Steps In, and Mueller Is Safe for Now, New York Times (June 13, 2017); see Sanders

7/3/18 302, at 6 (Sanders spoke with the President directly before speaking to the press on Air Force

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J r.’s statement.729 Alter consulting with the President on the issue, White House Press Secretary Sarah

Sanders told the media that the President “certainly didn’t dictate” the statement, but that “he weighed

2017) (“I do want to be clear—the President was not involved in the drafting of the statement”). 73° Sarah

Sanders, White House Daily Briefing, C~SPAN (Aug. 1, 2017); Sanders 7/3/18 302, at 9 (the President told

Sanders he “weighed in, as any father would” and knew she intended to tell the press what he Said).

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Department of Justice Wed-netfl Also on January 26, 2017, Hicks recalled that the President asked Sanders

to contact McGahn about the story.789 McGahn told Sanders there was no need to respond and indicated

Sanders did not recall whether the President asked her to speak to McGahn or if she did it on her own

Sanders 7/23/18 302, at 2. 79° Sanders 7/23/18 302, at 1-2. 79’ “Meet the Press Interview with Reince

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about the Manafort trial were widely covered by the press.866 When asked about the President’s tweets, Sanders

Later that day, when Sanders was asked about the President’s tweet, she told reporters, “It’s not an

Sarah Sanders, White House Daily Briefing, C-SPAN (Aug. 1, 2018). 36“ @realDonaidTrump 8/1/18 (9:34 am

“7 Sarah Sanders, White House Daily Briefing, C-SPAN (Aug. 1, 2018). .868 Chris Strohm & Shannon Pettypiece

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White House had “close[d] the door one way or the other on the President pardoning Michael Cohen,” Sanders

attorneys to comment on anything specific regarding that case, but we don’t have anything at this poin Sarah

Sanders, White House Daily Briefing, C-SPAN (Apr. 23, 2018). 1032 Cohen 11/20/18 302, at 7; Cohen 3/

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, Rod Rozov, Andrei Rtskhiladze, Giorgi Ruddy, Christopher Rybieki, James Samochornov, Anatoli Sanders

, Sarah Huckabee Sater, Felix Saunders, Paul J.