Mr. Schiff. And what privilege in particular, because you refer to a number of privileges? So, for this specific question—that is, whether Mr. Clark used personal devices to communicate government business—which specific privilege enables Mr. Clark to refuse to answer that question?
Mr. MacDougald. Given the lack of specificity of the question, we can do no more than allude to the privileges that are asserted in the letter, which are the full panoply of executive, Federal law enforcement, and so on, privileges that are in the letter, and plus the reservation that we've made. So, you know, I—again, with respect, Congressman, we do not want to engage in a debate or a law school set of hypotheticals about this.
Mr. Schiff. Well, counsel, you said my question wasn't very specific. Let me try to make it very, very specific.
Mr. Clark. did you use personal electronic devices to conduct government business while you were at the Department of Justice? Yes or no?
The Witness. This has been asked and answered, Representative.
Mr. Schiff. I don't have an answer, so would you please answer the question for me?
Mr. MacDougald. We would object based on privileges set forth in the letter, Congressman.
Mr. Schiff. And, counsel, which specific privilege entitles this witness to refuse to answer a question about whether he used personal devices—I'm not asking about the content, not asking about communications with the President, but merely the simple fact of whether he used personal electronic devices to conduct government business. What specific privilege are you asserting that gives him the right to refuse to answer that question?
Mr. MacDougald. We rest on the privileges asserted in the letter, Congressman.
