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nothing more than a continuation of the Greatest and most Destructive Witch Hunt of all time."[1]

B. President Trump released a redacted version of the classified anonymous whistleblower complaint.

Like the call summary, the anonymous whistleblower complaint was initially classified. The complaint was reportedly "hand delivered . . . to Capitol Hill" hours after President Trump released the call summary.[2] Although a limited number of Members of Congress—like Chairman Schiff—could access the classified complaint, the American public could not. The President released a redacted version of the anonymous whistleblower complaint so that every American could read it for themselves.[3]

C. President Trump released publicly the summary of his April 21 phone call with President Zelensky.

President Trump first spoke by telephone with President Zelensky on April 21, 2019, the date on which President Zelensky won the Ukrainian presidential election.[4] On November 15, the President publicly released the summary of this April conversation.[5] President Trump explained that he chose to release the summary of this call to "continue being the most transparent President in history."[6]

D. The Trump Administration has experienced a surge in sensitive leaks, including details of the President's communications with foreign leaders.

The Trump Administration has experienced an unprecedented number of potentially damaging leaks from the U.S. national security apparatus.[7] According to a report from the Senate Homeland Security and Governmental Affairs Committee in May 2017, these leaks have flowed seven times faster under President Trump than during former Presidents Obama and Bush's administrations—averaging almost one per day.[8] The report explained:

  1. ↑ Donald J. Trump (@realDonaldTrump), Twitter (Sept. 24, 2019, 11:12 a m.), https://twitter.com/realdonaldtrump/status/1176559970390806530.
  2. ↑ Dana Bash, et al, Whistleblower complaint about Trump declassified and may be released Thursday, CNN, Sept. 26, 2019.
  3. ↑ Whistleblower complaint says White House tried to "lock down" Ukraine call records, CBS News, Sept. 26, 2019.
  4. ↑ Memorandum of Telephone Conversation, supra note 10.
  5. ↑ Mark Mazzetti & Eileen Sullivan, Rough transcript of Trump's first phone call with Ukrainian leader released, N.Y. Times, Nov. 15, 2019.
  6. ↑ Donald J. Trump (@realDonaldTrump), Twitter (Nov. 11, 2019, 3:35 p.m.), https://twitter.com/realDonaldTrump/status/1194035922066714625.
  7. ↑ HSGAC report, supra note 409.
  8. ↑ Id.

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