cover of episode The Truman Precedent

The Truman Precedent

Publish Date: 2024/1/23
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Hello, welcome back to another episode of Prosecuting Donald Trump. It's Tuesday, January 23rd. I'm here with Mary McCord. I'm Andrew Weissman. Hi, Mary. Good morning, Andrew. So there's a lot to talk about even while we're waiting for the D.C. Circuit to come down with their immunity decision. We're going to talk about the E. Jean Carroll case because there's a lot going on. And I actually...

was there, the last day of the trial was actually sitting. I was actually in court. So we'll talk about that. Yeah, I can't wait to hear your sort of first person account of what so many of us just heard about later on through the news and through reading about it and hearing how Judge Kaplan reacted to some of the shenanigans in court.

We'll also talk about a new filing in the Mar-a-Lago classified documents case. This is Mr. Trump's motion to compel discovery. And it's similar in some ways to a motion to compel discovery that he filed in the January 6th related case, taking a very, very broad view of what he's entitled to. But it's not utterly without merit. Yeah, that's that's sort of a sleeper case because everyone's sort of assuming that it's not going to go in May. And that's probably right.

It's still worth keeping an eye on, though, because there's been a bunch of activity. And then we're going to sort of briefly talk about what's going on in other news. There's a lot that we're expecting to be filed by the end of January. So we'll briefly cover sort of what to keep an eye on next week. That's going to be coming down the pike. But Mary, do you want to talk for a moment about something that kind of relates to the D.C.?

decision that we're waiting for on presidential immunity. And we spent a lot of time talking about that oral argument. Yeah. Hopefully, if the opinion doesn't come out today, people weren't listening to the part where I said it would be within one to two weeks because two weeks is today. So I still have some time. You first said you first said a week.

And then when I said, I can't believe what a bad influence I am on you. Then I modified it. You're right. I modified it to two weeks. Calling you out. Yep.

I actually thought it would be out by now. I think one of the reasons for delay is there are three judges and it's an important decision. So I imagine it's not the same as one judge issuing just her decision and having exclusive control over it. But something related to the argument, and if you remember the argument that Donald Trump made was that essentially it's like an impeachment first argument, which is that he can only be criminally charged

if there is a successful impeachment, meaning he's impeached and convicted, then he could be charged with Corral Matters. But if that doesn't happen, he's completely immune. Well, over the weekend, Donald Trump basically trotted out what I would refer to as the Truman defense. Right. Let's play that so people can hear it. Let's hear that. Yep. You have to have a guaranteed immunity for a president. Otherwise, a president's not going to be able to function.

They're not going to move. Harry Truman would not have done. Harry Truman would not have done Hiroshima. Nagasaki probably ended the war. Probably. I think so. But he wouldn't have done it. So many things wouldn't be done. The president has to have immunity. If if they don't have immunity, you're not going to have you're not going to have a presidency much. You're not going to have much of a country.

So listen, I mean, I think most people would recognize how completely apples and oranges these things are. And clearly what he's trying to do with this type of reference to the atomic bomb and Truman's decision ultimately to drop the atomic bomb during a war, he's trying to convince the American people that things like doing what is considered

considered by our military and our government to be necessary during war could be thwarted if presidents didn't have immunity. But even more significantly, I think he's trying to make it seem like without immunity, presidents have absolutely no ability to act across the board to do anything, which is ridiculous just from the perspective of

you just don't need to commit crimes to be president. You don't need to commit crimes in order to prosecute a war during a declared war. You don't need to commit crimes to challenge an election. You just don't need to commit crimes to do any of that. But two legal points I'd make. One is that

Things in wartime are governed by the law of war. They're not really governed distinctly and directly by U.S. law. The international treaties provide for the law of war, which is based on principles of military necessity, distinction, humanity, and proportionality. And, you know, people have and reasonably can criticize Truman's decision to drop those bombs.

as being excessive, being not in compliance with proportionality under international human rights law and law of war. But that is very separate thing from whether a president needs U.S. criminal immunity from those actions.

And secondly, our criminal code does sometimes provide for extraterritorial application of criminal code. And by that, I mean application to acts that take place outside the United States, but not in a situation like this. So a U.S. national who kills another U.S. national outside the United States can be prosecuted in the United States. But that's not what we're talking about here either. So I just think even from once we get

pull away from sort of the rhetorical value that he thought it had. It just has no real legal value. You know, I think it's so great to have that sort of sober, dispassionate discussion because it's so preposterous just to do the legal piece and then talk about the way in which he's using it. Harry Truman

in fact, made those hard decisions at a time when it was a given, and it still is a given, that American presidents are not above criminal, the American criminal laws. What he did was not, in fact, a violation of American criminal law, and he had no trouble making those decisions given the state of the law at the time. So if Donald Trump's point is, oh, we need to have this because otherwise,

Harry Truman wouldn't have been able to make this very tough call, that is demonstrably not true. What he's really saying is, can you please just give me immunity so I don't have to be tried in four criminal cases? The impact on the presidency is sort of a secondary point that he needs to use as a vehicle. I think strategically, it is probably...

a horrendous thing to say in terms of the pending case that he has in the D.C. Circuit and potentially in the Supreme Court, because there's no way that judges are not listening to and hearing and being exposed to how far he would take this kind of criminal immunity if it was granted. And it would be a terrible, slippery slope. So

I think it was strategically not a good idea, but I think what he's doing is he's really running as a lawless authoritarian outlaw. And he's basically just going to the people saying, you know, it's fine to have a Victor Orban, which he keeps on sort of praising in the New Hampshire primary.

That's the Hungarian dictator, really, for lack of a better word. So, I mean, he's really using this as a make no mistake as to what I am going to be and what I want as president. And so I...

think there is just going to be an incredibly stark decision for the electorate based on the kinds of things he's saying. I think that's sort of his big picture strategy. And to that point, you know, about him sort of using such outrageous, really, examples of what you would need immunity for to talk about

a decision made during a declared war. Recall as well that Jack Smith in his opposition brief to Trump's brief claiming immunity set forth a whole litany of pretty outrageous things that someone with immunity from criminal prosecution along the lines of what

Trump indicated that he was seeking things that a president could do that I think we would all be pretty aghast at any president doing. Absolutely. So, Mary, why don't we take a quick break and then let's talk about the E. Jean Carroll case and what's going on there. Yes, absolutely.

MSNBC's Lawrence O'Donnell. I have an obligation to find a way of telling this story that is fresh, that has angles that haven't been used in the course of the day, to bring my experience working in the Senate, working in journalism, to try to make sense of what has happened and help you make sense of what it means to you. The Last Word with Lawrence O'Donnell, weeknights at 10 p.m. Eastern on MSNBC.

Welcome back. Before we get into Andrew's firsthand experience in court, let's just remind listeners why this is the second defamation trial brought by E. Jean Carroll against Donald Trump. The first trial was earlier in 2023. It resulted in a jury determining that, yes, Donald Trump had sexually assaulted E. Jean Carroll and had defamed her.

by lying about that. And the jury returned

damages in total of $5 million. I believe $2 million of that was in compensatory damages, compensating her for losses she had suffered as a result of that defamation. And $3 million of that was punitive damages, which are supposed to be a deterrent. But as we know, Mr. Trump continues really to this day, and you can probably speak to this, Andrew, to defame E. Jean Carroll. The second defamation trial, oddly enough, is about

defamation that is alleged to have occurred chronologically in time before the defamation that was tried in the first defamation trial. And that's because the first defamation trial was about statements that Mr. Trump made after he was no longer president. And so that case did not get hung up in appeals like the first case that was about statements that he made when he was the president.

because that case got hung up in appeals over various issues, including the Department of Justice

starting out by defending him in that case. And so that one finally has cleared all of those appeals, was cleared to go forward. And so that one, the chronologically first instances of defamation are being tried chronologically second. So one can understand why someone might be confused about what this trial is about. Absolutely. So Carol 1 is actually going, appears to be Carol 2. That's right. And that

explains why some people may be interested in sort of the judge in what I'll call Carol 1, which is the case that's going on right now, has said that there's certain issues that are already decided. And that's because there was a trial. Donald Trump and E. Jean Carroll had their day in court. They had the opportunity to present any and all evidence. They had the opportunity to testify, as you'll remember, E. Jean Carroll testified, Donald Trump testified,

did not. And the jury came back unanimously finding that Donald Trump sexually assaulted and defamed E. Jean Carroll. So under the law, that is a collateral estoppel. That means that it's been decided

There is no mulligan. There's no do over. Right. How do you like that sports analogy? I like it. It's good. I'm not particularly known for sports. Yeah. I just didn't know you were a golfer. It's good to keep people guessing. Yes, that's right. So he doesn't get to take another shot and hope this jury will find that he did not sexually assault her and he did not lie about it. Exactly. Because guess what? You had your day in court.

It's not like you didn't get due process. It's not like you didn't have an opportunity. So that's why the judge has said those issues are decided. But what's not been decided is with respect to the two statements that E. Jean Carroll says were defamatory, what is the additional, if any, compensation, either as compensatory damages or penalizing?

punitive damages. And the punitive part is particularly interesting because, as you said, the bizarre part of what is going on is that Donald Trump, to this day, I'm sure today, as we're talking, Mary, continues to make statements about Egypt and Cairo

continue the defamation. And one of the oddities on Thursday when I was in court, which is the last day of an actual trial day because there was no sitting on Friday. And then Monday and today, Tuesday, there were issues with the sickness of a juror of one of Donald Trump's defense lawyers being ill, requesting also that time be off because of the New Hampshire primary. But for the earliest it will start is to

tomorrow, assuming everyone's well. But what's so odd on Thursday is there was almost real-time evidence coming in because it's like, oh, E. Jean Carroll's like, judge, we're going to put in evidence about what just happened. The last time that happened is you'll remember when we had Michael on to talk about the Rudy Giuliani case where we played a clip of what Rudy Giuliani said on the first day of trial. And he told us how that clip that we played on

on this podcast was actually played to the jury. So that kind of statement. And just to be clear, that involved things that Mr. Giuliani was saying outside the courtroom during his trial that really was important evidence about his own defamation of Ruby Freeman and Shea Moss.

Absolutely. That kind of evidence is relevant, obviously, to the punitive damages component that the jury will have to decide because the point of punitive damages is what kind of damages are needed to punish the person and deter them from continuing to make these kinds of statements. So relevant to that is, is the person continuing or are they contrite? So of course he's not contrite. One of the things that E. Jean Carroll testified to is he

She has security with her. She has a gun.

that she keeps by her side, there are death threats that she receives. I mean, it was really chilling testimony. It was another example of what we heard from Ruby Freeman and Shea Moss in a different context. It's what we know is going on with election workers, with secretaries of state, of judges, prosecutors. It's rampant, the idea that violence is an acceptable crime.

reaction. And just to be a little bit on my high horse, what is also rampant is Republicans who don't feel the need to say that is unacceptable. It's just so remarkable to me that that is not sort of a baseline. You can completely disagree with somebody politically. I mean, that's totally fine. The idea that that's not something that everyone can agree on and call out is just

tells you that people are really buying into Trump's rhetoric and how much he inures us to violence as an appropriate response. Yeah. And I think, you know, it also shows that there's maybe no amount of money that will deter him from continuing to engage in the type of defamation and lies that he tells on a daily basis, which to me means he he thinks it's more important to

to his ultimate goal, which is, I think, to stay out of jail, to continue telling these lies and to have the American people who he appeals to be willing to go to the polls and vote for him and soundly reject any kind of notion that the criminal cases are valid or legitimate and call them witch hunts. I mean, it's part of

what his entire plan and mission is right now is to convince the significant percentage of the American public that none of this is valid and that he should be the next president and he shouldn't be being prosecuted. Couldn't agree more. Yeah. The other interesting thing, and I don't think these have been ruled on yet, is there were motions made and maybe this was while you were in court. I don't know, Andrew, but

Mr. Trump's lawyer, Alina Haba, you know, moved to have the entire case thrown out, arguing that E. Jean Carroll had an obligation to save every death threat that she got, including those that she received on the same day that Trump made his very first defamatory statements about her in 2019, before she even had any idea that she would bring a lawsuit. Yeah. So just so people know, you could make that

motion and have a chance of winning if it was absolutely clear that you are under an obligation to preserve documents relevant to a case. So, for instance, if you got a discovery demand or a subpoena, or if it was clear that was going to happen, then you have an obligation to not destroy relevant evidence. For example, suppose you had had a subpoena, such as the subpoena issued to Mr. Trump at Mar-a-Lago,

to return classified documents. And you later conspired to destroy and obstruct those or obstruct the finding of those documents and destroy evidence

that would be something that, you know, could result in a penalty. Yes. So it's the irony is rich. Yes, it is. Exactly, Mary. So here, though, there was nothing to say that these were, one, that there was an obligation to preserve. Two, that E. Jean Carroll knew that there was an obligation to preserve. Three, that the material isn't available through other sources.

Just because you got rid of them on your computer doesn't mean that they're not available by going to Twitter or to your email provider. Four, that you had the opportunity to depose the person and ask about all of this. So this is one where, as a judge in the district I sort of grew up in, used to say, I have two words for you.

Denied. Right. Right. So one very quick thing before we move on. I just wanted to talk a little bit about the people are thinking that Donald Trump has said he wants to testify this time. Yep. And he did not testify in the first trial. Exactly. Jurors saw and heard from him by seeing clips of his deposition, as I recall. Yeah. Which, you know...

Didn't go well. No, it didn't go well. It didn't go well. That's probably the best way to put it. That's where he basically said, you know, it's been centuries of human history where famous people have sexually abused women for good or bad. Yep. That was my favorite. For good. It's like, tell me about that for good part. It's just shocking. But anyway, he has said that he wants to testify.

But as we mentioned, Judge Kaplan has said there are only certain things that you can testify to. For instance, you don't get a do-over. So you don't get to say, I didn't do it and she's lying and all of that. That's been decided. You had your day in court. But obviously, everyone knows that Donald Trump would hop on the stand and say that. Just to be clear, let me give you two data points for who this judge is, Judge Kaplan. And I'm going to give you two things that he has done in prior trials so that you understand the kinds of levers he has

to prevent this from happening. One, in the Sam Bankman Freed case, it's a very, very big white collar criminal case. A couple of months ago where Sam Bankman Freed, crypto guy was convicted, he wanted to make various claims about advice of counsel. But it

But it was not clear that he really had an advice of counsel defense. So what the judge did is said, you know what? Kicking the jury out for the moment, I'm going to have you testify outside the presence of the jury. I want to hear what you're going to say. And then he ruled on it and said, nope,

That's not coming in. And so he could do the same kind of pre-screening. And in many ways, that might be good for both sides. Donald Trump gets to say, see, I'm denying this happened, but they won't let me put it in. Right. He'll make that sort of right. I'm still a victim. On the other hand, from E.G. Carroll and even the government's perspective, he gets cross examined. And so that may not go very well in terms of he's going to have to answer those questions unanswered.

under oath. And the E. Jean Carroll team is excellent, really top-notch lawyering. So, you know, this is not going to be an easy road for him. Okay, second data point. If somebody takes a stand and says something that's false, there is a case involving Mr. Donziger, who was making claims with respect to

a dispute he had with Chevron, huge oil company. And this ended up before Judge Kaplan. And Judge Kaplan thought that Mr. Donziger had committed contempt that has violated his orders. And you know what he did? He appointed a special prosecutor to criminally charge Mr. Donziger, and he was convicted. It's risky. It is risky. And this judge is...

a serious, hard nose. But by the way, one of the reasons I went to trial is I wanted to see, was he being fair to both sides? Like, how much was Alina Haba and that sort of lawyer getting under his skin? It was remarkable.

how even keeled he was. And I mean, I was I shouldn't have been surprised. I mean, he was so solicitous and yet tough. Just what you want in a judge, you know, can be hard, but it's like basically, you know, have your ducks in a row when you come to court. He's not going to let his courtroom be manipulated, which is what not only Mr. Trump wants to do, but Alina Haba as well. I mean, we haven't even talked about yet this podcast about

you know, the muttering and mumbling, you know, within earshot of the jury of Mr. Trump that, you know, really got squashed. Yep. Yep. Absolutely. Let's take another break and we'll come back and talk about Mar-a-Lago and what's on our dance card in terms of things to keep an eye out for. You bet.

MSNBC's Lawrence O'Donnell. I have an obligation to find a way of telling this story that is fresh, that has angles that haven't been used in the course of the day, to bring my experience working in the Senate, working in journalism, to try to make sense of what has happened and help you make sense of what it means to you. The Last Word with Lawrence O'Donnell, weeknights at 10 p.m. Eastern on MSNBC.

Welcome back. So, Mary, let's talk about what's going on in the Mar-a-Lago case, the sort of sleeper case that people have sort of put to the wayside because we don't really know if that's going to go on the tentative date in May. What's going on? What kind of filings have been made? So, you know, one of the biggest filings recently has been a 68-page motion to compel Discovery and

filed by Mr. Trump. And as I said at the top, it reminds me a little bit of the lengthy motion that Mr. Trump also filed through his lawyers in the January 6th related cases.

So these are motions where they're claiming that the prosecution has taken too narrow a view of the prosecution team because a defendant in a criminal case is entitled not only to discovery generally of information, records, documents, digital information, anything that could be relevant to his defense, including documents that are in the custody of the government and were created by the government,

But they're also entitled under not just discovery rules, but due process principles of the U.S. Constitution to any information that is exculpatory or impeaching. So exculpatory meaning tending to show that you did not commit the crime or impeaching meaning tending to discredit any evidence or any witnesses that the government have against you.

And so that type of information we call Brady information, Brady for exculpatory and Brady sort of more generally. But if you want to get explicit in breaking out the impeachment type of evidence that's referred to as Giglio or some people say Giglio, that's another one of these questions that the I say Giglio. What do you think? I think. Well, I think I told you that I did say this story before, but now I can't remember which way you say it. Well, I had said I can't remember. I had said Giglio or Giglio, but that.

defense lawyer getting under my skin said he represented that defendant in the Supreme Court. He was his client. And he said, Giglio. That's right. That's right. But see, I can't remember that. I've said Giglio for too many years. Giglio. And by the way, based on our last week's episode, I had a million people tell me about the Bronx. Oh, oh, that's right. Yes. Right. Did anybody have a good explanation? Yeah. You know what? Only

almost everybody had the same explanation. Okay. Which, you know, I kind of thought, okay, maybe I should have gone to the Google and looked it up. The Google. The Google, right. It's like the internets. So according to our crowdsourcing this, it turns out that it is based on

Netherlands family that lived in the Bronx. And it's the way you would say the McCords or the Weissmans. It was the Bronx spelled slightly differently, but then, you know, Americanized to B-R-O-N-X. And so it's just a reference to the family. Oh, my goodness. So that really made a lot of sense.

And, you know, there was no the Manhattans or the Brooklins because it wasn't a family. So that's the answer. Okay. Thank you, everyone who chimed in. The crowdsourcing was great. Anyway, I think I might have engaged in a little bit of a digression. Yeah. Yeah. But it was so worth it. Just a little bit. Yeah. Okay.

So at any rate, kind of like he filed in the January 6th reading case, he said, look, the government's being too narrow in what they consider the prosecution team where they should be disclosing evidence from a much broader set of government agencies. And here in particular, he's trying to make an argument

And it's fairly direct, only very thinly veiled that basically, you know what? It's not veiled at all. That the Biden administration, Joe Biden personally is directing this investigation, this criminal prosecution and doing so because they are political opponents. And so what he's trying to argue, at least in the introduction to this motion to compel, is that we need all

kinds of information from the White House, the National Archivist, the whole intelligence community, you know, all of the U.S. Attorney's Office and the Department of Justice and the FBI who's been involved in this investigation and prosecution. And we need to make sure that the government is turning over all communications that might

tend to show some sort of inappropriate direction from the White House. Now, I will say, even though the introduction reads much more like sort of a not a legal document, but something that I don't want to say something Mr. Trump would say on the campaign trail because he would be way more inflammatory than the introduction. But the introduction makes a point very strongly, I think. I mean, here's what it says.

The special counsel's office has disregarded basic discovery obligations and DOJ policies in an effort to support the Biden administration's egregious efforts to weaponize the criminal justice system in pursuit of an objective that President Biden cannot achieve on the campaign trail, slowing down President Trump's leading campaign in the 2024 presidential election.

So you can forget listening to me trying to describe in other terms what this intro says. But it is true that in a case like this, where you had it start out

with the archives recognizing they were missing presidential records, obtaining those records, realizing there was classified information in them, realizing they needed to refer that to the Department of Justice and FBI, and also even to folks within the White House because of the importance and the significance of there being classified documents that were not in places that they should be stored. That presents a vulnerability to national security. The intelligence community had to get involved.

So there is a very big group of government entities that has had some involvement at some point in time in the precursors to this criminal case. So it's not crazy to my mind to say, you know, these are all places where the government should be producing information that's relevant under either the discovery rules or Brady or Giglio. Yeah, Giglio. So, Mary, I couldn't agree more.

One thing to note is we do not yet have the government's response. That's right. I think both of us are sort of in the same mind that we'd be surprised if the response isn't, yeah, that's why we look there and that's why we turn that all over. That's right. But if you're asking us to look at the probation office in Seattle, Washington, we're not doing that because it has no logical relevance. Right.

But I sort of viewed this motion as how do we provide a fig leaf to Judge Cannon to delay this case and overload her with motions and arguments so that she can say, oh, see, there's a lot that I still have to decide. Right. I just want to give a quick note on one of the things that the government did is they moved to unseal the full search warrant. That is something that Donald Trump actually asked for. And yet that is something that the Trump team criticized as being unfair. Right.

to Donald Trump to unseal a document that he had previously asked to be unsealed. Right. And so, you know, of course, none of this is consistent. All of this is just a question of fodder outside of the courtroom for his victimization tour. Right. But let's just focus on for a moment, I think, on what is about to come up. And Mary, in preparing for this, we were both sort of struck by January 31st. Yeah, a lot happening that day. A little more than, I guess, a week away. What

What's on the dance card for January 31st people should keep an eye out for? So the biggest thing I'm keeping an eye out for will be the opposing brief filed by the what were originally the plaintiffs in the Colorado 14th Amendment Section 3 disqualification case. So you'll recall that the Colorado Supreme Court held that Mr. Trump is disqualified from holding the office of the presidency under the 14th Amendment Section 3 for having engaged in insurrection against the Constitution.

Mr. Trump appealed that to the Supreme Court. The Supreme Court accepted that case for appeal, set a highly expedited briefing schedule. Mr. Trump filed his brief last week, which really didn't raise any new arguments, sort of fleshed out arguments we'd seen already in the Colorado courts.

The government's brief is due on January 31st, thus our focus on January 31st. And then February 5th, Trump will have a chance to reply to that. And then it goes to argument three days later. So the Supreme Court is going to be speed reading through the briefs. There's also been already many, many, many, many amicus briefs, friend of the court briefs filed in this case. So a lot that will be in front of the court. And we will talk more about sort of the substance of the arguments when we get the full briefing, I think. But

But that's not all on January 31st. Yep. So other things on the 31st are, just to go back to the Mar-a-Lago case, the court is going to be hearing from the government under seal ex parte, meaning just the government and the court in connection with its SEPA, the classified information section 4.0.

provisions. And then there'll be continued litigation about that. But that is a standard part of the classified litigation. And that's something that we thought was going to happen and, in my view, should have happened two months ago. Months ago. Yeah, exactly. But it's going to finally happen on the 31st. The

The other thing that is supposed to happen by the 31st is Judge Ngoran had said in connection with the New York Attorney General civil fraud case that he was hoping, aspirationally, to have his decision by the 31st. So it's not set in stone, but that's also scheduled for the 31st. And in case that isn't enough, on February 2nd and then for days after that, there is going to be filings in the Georgia criminal case in connection with the

the argument by Michael Roman, a defendant there, making allegations about Fannie Willis and an alleged improper relationship with an outside special prosecutor was hired. I keep on phrasing it that way because we don't yet have a full sort of accounting of what the proof is and what Fannie Willis is going to say happened and didn't happen. So that's another thing on the second to keep your eye out. So there's a lot that's going to be filed to keep us busy.

Big, big main issue, Mary, that just to go back to where we began is we're still on tenterhooks waiting for the D.C. circuit. Yes, absolutely. Yep. Ready to start speed reading as soon as it comes out. And, you know, it might just mean there's an emergency podcast. We'll have to see.

You're not going to make another prediction, Mary? I can't entice you? That's it. Producers are shaking their head no. Yeah, and I also feel like, Mary, you're like, you know what? I followed your lead. Didn't go too well. Yeah, I'm going to quit prognosticating. Yeah, absolutely. Not my forte. Okay, I'll talk to you either next week or maybe if there's a decision. Or sooner. Take care. Bye. Bye.

If you've got questions, you can leave us a voicemail at 917-342-2934. Maybe we'll play it on the pod. Or you can email us at prosecutingtrumpquestions at NBCUNI.com. Thanks so much for listening. We'll be back next week.

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