Mr. Donoghue, a policy on contacts with the White House?
A Yes. There is a White House contacts policy.
Q Generally describe what it says. What is the essential thrust of the White House contact policy that applies to personnel across the Department?
A Essentially what it does is it limits the contact between the White House and the Department to certain levels within the Department in order to ensure that there is some distance maintained between the White House and the Department. So it sets forth who can talk to personnel at the White House and what types of matters they can talk about.
Q I want to turn your attention, if I can, in your binder. And, for the record, we've provided your counsel with all the exhibits that we're going to use in advance. And if you could just turn to exhibit 1, to an email, Mr. Donoghue, that you sent on November the 11th of 2020 at 6:27 p.m. Do you see that document in front of you?
A Yes. I have it.
Q Okay. Tell us what that is.
A It's an email I sent out on Veterans Day, November 11th, at 6:27 in the evening, to the Assistant Attorneys General, the AAGS, who ran different components within the Main Justice headquarters in Washington.
Q Good. So Assistant Attorneys General, to be clear, are the component heads. There's one for civil rights and one for antitrust and one for civil, for all the litigating divisions of the Department?
A Correct.
Q And you sent this email to them, and tell us what was attached to the email.
A The DOJ White House contacts policy—
Q In the—
