Congress Sends Letter To White House To See If Vice President Pence’s Stay At A Trump Golf Resort in Ireland Benefitted the President

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Submitted: September 06, 2019

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Submitted: September 06, 2019



Congress Sends Letter To White House To See If Vice President Pence’s Stay At A Trump Golf Resort in Ireland Benefitted the President


Vice President Pence stayed at Trump International Golf Links & Hotel in Doonberg, Ireland while on a taxpayer funded official trip to Ireland (Conflicts of Interest; Emoluments).

Responding to Committee Document Requests

1. In complying with this request, produce all responsive documents that are in your

possession, custody, or control, whether held by you or your past or present agents,

employees, and representatives acting on your behalf. Produce all documents that you

have a legal right to obtain, that you have a right to copy, or to which you have access, as

well as documents that you have placed in the temporary possession, custody, or control

of any third party.

2. Requested documents, and all documents reasonably related to the requested documents,

should not be destroyed, altered, removed, transferred, or otherwise made inaccessible to

the Committees.

3. In the event that any entity, organization, or individual denoted in this request is or has

been known by any name other than that herein denoted, the request shall be read also to

include that alternative identification.

4. The Committees’ preference is to receive documents in electronic form (i.e., CD,

memory stick, thumb drive, or secure file transfer) in lieu of paper productions.

5. Documents produced in electronic format should be organized, identified, and indexed


6. Electronic document productions should be prepared according to the following


a. The production should consist of single page Tagged Image File (“TIF”), files

accompanied by a Concordance-format load file, an Opticon reference file, and a

file defining the fields and character lengths of the load file.

b. Document numbers in the load file should match document Bates numbers and

TIF file names.

c. If the production is completed through a series of multiple partial productions,

field names and file order in all load files should match.

d. All electronic documents produced to the Committees should include the

following fields of metadata specific to each document, and no modifications

should be made to the original metadata:









7. Documents produced to the Committees should include an index describing the contents

of the production. To the extent more than one CD, hard drive, memory stick, thumb

drive, zip file, box, or folder is produced, each should contain an index describing its


8. Documents produced in response to this request shall be produced together with copies of

file labels, dividers, or identifying markers with which they were associated when the

request was served.

9. When you produce documents, you should identify the paragraph(s) or request(s) in the

Committees’ letter to which the documents respond.

10. The fact that any other person or entity also possesses non-identical or identical copies of

the same documents shall not be a basis to withhold any information.

11. The pendency of or potential for litigation shall not be a basis to withhold any


12. In accordance with 5 U.S.C.§ 552(d), the Freedom of Information Act (FOIA) and any

statutory exemptions to FOIA shall not be a basis for withholding any information.

13. Pursuant to 5 U.S.C. § 552a(b)(9), the Privacy Act shall not be a basis for withholding


14. If compliance with the request cannot be made in full by the specified return date,

compliance shall be made to the extent possible by that date. An explanation of why full

compliance is not possible shall be provided along with any partial production.

15. In the event that a document is withheld on the basis of privilege, provide a privilege log

containing the following information concerning any such document: (a) every privilege

asserted; (b) the type of document; (c) the general subject matter; (d) the date, author,

addressee, and any other recipient(s); (e) the relationship of the author and addressee to

each other; and (f) the basis for the privilege(s) asserted.

16. If any document responsive to this request was, but no longer is, in your possession,

custody, or control, identify the document (by date, author, subject, and recipients), and

explain the circumstances under which the document ceased to be in your possession,

custody, or control.

17. If a date or other descriptive detail set forth in this request referring to a document is

inaccurate, but the actual date or other descriptive detail is known to you or is otherwise

apparent from the context of the request, produce all documents that would be responsive

as if the date or other descriptive detail were correct.


18. This request is continuing in nature and applies to any newly-discovered information.

Any record, document, compilation of data, or information not produced because it has

not been located or discovered by the return date shall be produced immediately upon

subsequent location or discovery.

19. All documents shall be Bates-stamped sequentially and produced sequentially.

20. Two sets of each production shall be delivered, one set to the Majority Staff and one set

to the Minority Staff. When documents are produced to the Committee on Oversight and

Reform, production sets shall be delivered to the Majority Staff in Room 2157 of the

Rayburn House Office Building and the Minority Staff in Room 2105 of the Rayburn

House Office Building. When documents are produced to the Committee on Financial

Services, production sets shall be delivered to the Majority Staff in Room 2129 of the

Rayburn House Office Building and the Minority Staff in Room 4340 of the O’Neill

House Office Building. When documents are produced to the Permanent Select

Committee on Intelligence, production sets shall be delivered to Majority and Minority

Staff in Room HVC-304 of the Capital Visitor Center.

21. Upon completion of the production, submit a written certification, signed by you or your

counsel, stating that: (1) a diligent search has been completed of all documents in your

possession, custody, or control that reasonably could contain responsive documents; and

(2) all documents located during the search that are responsive have been produced to the



1. The term “document” means any written, recorded, or graphic matter of any nature

whatsoever, regardless of how recorded, and whether original or copy, including, but not

limited to, the following: memoranda, reports, expense reports, books, manuals,

instructions, financial reports, data, working papers, records, notes, letters, notices,

confirmations, telegrams, receipts, appraisals, pamphlets, magazines, newspapers,

prospectuses, communications, electronic mail (email), contracts, cables, notations of any

type of conversation, telephone call, meeting or other inter-office or intra-office

communication, bulletins, printed matter, computer printouts, teletypes, invoices,

transcripts, diaries, analyses, returns, summaries, minutes, bills, accounts, estimates,

projections, comparisons, messages, correspondence, press releases, circulars, financial

statements, reviews, opinions, offers, studies and investigations, questionnaires and

surveys, and work sheets (and all drafts, preliminary versions, alterations, modifications,

revisions, changes, and amendments of any of the foregoing, as well as any attachments

or appendices thereto), and graphic or oral records or representations of any kind

(including without limitation, photographs, charts, graphs, microfiche, microfilm,

videotape, recordings and motion pictures), and electronic, mechanical, and electric

records or representations of any kind (including, without limitation, tapes, cassettes,

disks, and recordings) and other written, printed, typed, or other graphic or recorded

matter of any kind or nature, however produced or reproduced, and whether preserved in

writing, film, tape, disk, videotape, or otherwise. A document bearing any notation not a


part of the original text is to be considered a separate document. A draft or non-identical

copy is a separate document within the meaning of this term.

2. The term “communication” means each manner or means of disclosure or exchange of

information, regardless of means utilized, whether oral, electronic, by document or

otherwise, and whether in a meeting, by telephone, facsimile, mail, releases, electronic

message including email (desktop or mobile device), text message, instant message,

MMS or SMS message, message application, or otherwise.

3. The terms “and” and “or” shall be construed broadly and either conjunctively or

disjunctively to bring within the scope of this request any information that might

otherwise be construed to be outside its scope. The singular includes plural number, and

vice versa. The masculine includes the feminine and neutral genders.

4. The term “including” shall be construed broadly to mean “including, but not limited to.”

5. The term “Company” means the named legal entity as well as any units, firms,

partnerships, associations, corporations, limited liability companies, trusts, subsidiaries,

affiliates, divisions, departments, branches, joint ventures, proprietorships, syndicates, or

other legal, business or government entities over which the named legal entity exercises

control or in which the named entity has any ownership whatsoever.

6. The term “identify,” when used in a question about individuals, means to provide the

following information: (a) the individual’s complete name and title; (b) the

individual’s business or personal address and phone number; and (c) any and all

known aliases.

7. The term “related to” or “referring or relating to,” with respect to any given subject,

means anything that constitutes, contains, embodies, reflects, identifies, states, refers to,

deals with, or is pertinent to that subject in any manner whatsoever.

8. The term “employee” means any past or present agent, borrowed employee, casual

employee, consultant, contractor, de facto employee, detailee, fellow, independent

contractor, intern, joint adventurer, loaned employee, officer, part-time employee,

permanent employee, provisional employee, special government employee,

subcontractor, or any other type of service provider.

9. The term “individual” means all natural persons and all persons or entities acting on

their behalf.

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