[00:00:00] Speaker 02:
Case number 24-3006, United States of America versus Peter Canavarro, a valent.

[00:00:06] Speaker 02:
Mr. Branford, a valent.

[00:00:09] Speaker 02:
Good afternoon.

[00:00:10] Speaker 03:
Good afternoon.

[00:00:11] Speaker 03:
May it please the court?

[00:00:12] Speaker 03:
The valent, Peter Canavarro, having served his sentence and returned to public service, we're here on his behalf to raise what we think are important issues

[00:00:25] Speaker 03:
representing the first time that the 1857 congressional contempt statute has been used to prosecute a senior White House aide for contempt of Congress.

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Since at least 1983, when the US House of Representatives, the Department of Justice has consistently declined to use the criminal statute to prosecute any executive official in cases in which presidential privilege has been implicated.

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The courts in this circuit at both the appellate level and the district court level have consistently encouraged, yay, admonished both the legislative and executive branches to attempt to resolve these disputes between them over privilege without court intervention.

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preliminarily in USVAT&T, where they admonished each branch to take cognizance of an implicit constitutional mandate to seek optimal accommodation.

[00:01:27] Speaker 00:
But Mr. Navarro never took advantage of that particular process, is that correct?

[00:01:32] Speaker 03:
Well, he tried.

[00:01:34] Speaker 00:
How so?

[00:01:34] Speaker 00:
You have to show up first, right?

[00:01:36] Speaker 03:
No, he informed the committee staff that he thought he was bound by privilege.

[00:01:44] Speaker 00:
But that was before receiving the actual documents or knowing what the testimony was going to be about and that it might have covered broader than what his actual communications or relationships or job duties were with the White House?

[00:01:57] Speaker 03:
Well, based on his his instructions or what he believed were his instructions from the president, he felt he was under he was duty bound to assert the privilege from the beginning as other people in the White House had done.

[00:02:11] Speaker 00:
And when you say from the beginning, are you talking about when the president made more of an express statement during COVID-19 or the beginning of perhaps his term with the president?

[00:02:22] Speaker 03:
Yeah, that's one of the things that we would say at least is circumstantial evidence of a claim of privilege.

[00:02:29] Speaker 03:
Now, we understand Judge Maeda rejected that and said we had to have a more formal and personal assertion, but certainly

[00:02:41] Speaker 03:
I think it's fair to say that this president has aggressively and categorically, as the McGahn case held, asserted executive privilege on all- But most privileges or immunity essentially require just kind of a case-specific circumstance so that you know what's before court.

[00:03:01] Speaker 00:
For example, an attorney-client privilege, you wouldn't just have blanket privilege.

[00:03:05] Speaker 00:
you know, the court might take it under consideration in camera what the documents are to determine if you're fairly asserting it, but there's something before the court and there's some authority from the respective privilege holder with respect to having the privilege.

[00:03:21] Speaker 03:
Yes, but here, of course, we never got before a court to parse the scope of the privilege

[00:03:28] Speaker 03:
The accommodation never occurred, and the committee decided to refer.

[00:03:32] Speaker 00:
You say accommodation didn't occur, but a person in responding to a subpoena should show up, and then you have the ability to assert whatever you believe is appropriate.

[00:03:42] Speaker 03:
That has never been the Department of Justice's position, at least with respect to testimonial privilege.

[00:03:49] Speaker 03:
The OLC opinion from July 2014 explained that that puts the witness in an untenable coercive position.

[00:03:58] Speaker 01:
Didn't Dr. Navarro acknowledge in the district court that a former official serving a former president, the testimonial immunity would at most be qualified and therefore there wasn't this blanket entitlement not to show up?

[00:04:16] Speaker 01:
I thought we just don't even have that immunity as described in the OLC opinion that you referenced.

[00:04:23] Speaker 03:
I think what we would say there, Your Honor, is I think in fairness, US v. Trump changed all that because it sealed off

[00:04:33] Speaker 03:
preclusive Article II powers from even criminal liability.

[00:04:41] Speaker 01:
Not for anybody below the president, only for the president.

[00:04:43] Speaker 03:
Well, that's not clear.

[00:04:45] Speaker 01:
Well, if it's not clear, you can't rest on it as a reason not to accommodate, not to show up, not to communicate over non-presidential communication aspects of the information side.

[00:04:57] Speaker 03:
Well, no one had determined yet which was non-presidential.

[00:05:00] Speaker 01:
How could they in cases like the EPA case, the individual who's been subpoenaed provides documents that can be reviewed by someone with authority in the White House.

[00:05:18] Speaker 01:
The decision is made, okay, all of these are okay to be released.

[00:05:21] Speaker 01:
And here are the ones with respect to which we're asserting privilege because they involve presidential communications.

[00:05:30] Speaker 01:
That is the burden of the recipient of the subpoena.

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cooperate with the accommodation process that you emphasize so centrally in your brief.

[00:05:42] Speaker 01:
But if the deponent doesn't or the recipient of the subpoena doesn't even do that, it's a little bit hard to see what accommodation could go forward.

[00:05:55] Speaker 01:
I mean, the staff said to Dr. Navarro, you know, we know there's a lot of information here that's outside of

[00:06:03] Speaker 01:
your communications with the president or advising the president.

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And so even assuming you have the claim that you have identified, we need to go forward with that.

[00:06:12] Speaker 01:
And he doesn't respond to that.

[00:06:14] Speaker 03:
The question would be there, though, who can make that decision?

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Can the Congress unilaterally make that decision?

[00:06:20] Speaker 01:
It's an accommodation process, as you mentioned, back and forth.

[00:06:23] Speaker 01:
And he was unwilling to engage in that.

[00:06:25] Speaker 03:
Well, he did explain to the committee staff that he was directing them to the White House counsel.

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He's not a lawyer.

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And he said, my hands are tied.

[00:06:35] Speaker 01:
He needs to go to the White House counsel.

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That notion that they're going to do that, that they're going to do the work for him.

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They did it in other cases.

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He's not the only person who was subject to subpoena by the committee.

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And there were other witnesses who were subpoenaed, who didn't show up, who didn't produce documents.

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And there was a back and forth.

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And they were referred for contempt.

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And the Justice Department decided not to prosecute them.

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And so I don't know how the balancing can occur without a representative of the president being involved or his lawyer being involved.

[00:07:18] Speaker 01:
Do we have anything in the record about whether, in those other cases, the committee reached out to White House counsel or White House counsel reached out to the committee?

[00:07:26] Speaker 01:
Did anybody in the White House try to reach out to the committee?

[00:07:29] Speaker 03:
I'm not aware of that, although I was counsel in one of the other cases.

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And I can tell you we had lengthy back and forth between ourselves as lawyers and the committee, which didn't result in an accommodation and did result in a referral, but not a prosecution.

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Turning to the district court.

[00:07:54] Speaker 02:
You can see that I just want to make sure I have this right.

[00:07:56] Speaker 02:
A couple of times that privilege has has to be involved in each case.

[00:08:04] Speaker 02:
Right when they get a subpoena, there has to be a privilege determination for that subpoena.

[00:08:09] Speaker 03:
I mean, that was Judge Maeda's view.

[00:08:11] Speaker 02:
There were concessions by you.

[00:08:14] Speaker 03:
Did you agree with that?

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The position we took in front of Judge Maeda was that there was enough other evidence.

[00:08:25] Speaker 02:
1109-1175.

[00:08:27] Speaker 02:
You conceded it has to be subpoena-specific invocation of privilege.

[00:08:32] Speaker 02:
It can't be blanket.

[00:08:33] Speaker 02:
yes and we would point just making sure you it sounded like you were now backtracking from well i won't backtrack i'll say there was other evidence in the record that doesn't that's got nothing to do with my question as to whether you agreed your litigation position in district court was that the invocation of executive privilege has to be something that was that was our position okay and it still is here yes okay

[00:08:58] Speaker 00:
And just to piggyback on that, would that not be a consultation with the president to then exert it in that particular circumstance?

[00:09:10] Speaker 03:
Well, our position in the evidentiary hearing, which the judge granted for the first time that I'm aware of in any of these cases,

[00:09:19] Speaker 03:
Our position in the evidentiary hearing was that he had had a conversation with the president, that the council to the committee had made statements about, come on down, we'll work around the privilege.

[00:09:36] Speaker 03:
He received a letter from President Biden's White House counsel, Jonathan Hsu, who seemed to infer that they were aware that a claim of privilege had been made.

[00:09:48] Speaker 03:
And so there were other things in the record to suggest.

[00:09:52] Speaker 00:
But the judge made a fine that there were not time parameters.

[00:09:56] Speaker 03:
They were not sufficient.

[00:09:58] Speaker 03:
The judge made his position was you need a formal and personal invocation of the privilege.

[00:10:05] Speaker 03:
And while

[00:10:08] Speaker 03:
What we submitted was sufficient to get us to an evidentiary hearing or provided at the, it was not sufficient for him to find that privilege had been invoked.

[00:10:25] Speaker 02:
I mean, it is the president's privilege.

[00:10:27] Speaker 02:
It's a privilege that belongs to the president, correct?

[00:10:30] Speaker 02:
Yes.

[00:10:30] Speaker 02:
It's the president's to invoke or not, right?

[00:10:33] Speaker 02:
The president can decide to invoke it or not in any given situation.

[00:10:37] Speaker 03:
Yes, although there is language in some of the cases in this circuit that suggests that the privilege, while it certainly could be waived,

[00:10:49] Speaker 03:
It's not necessary for an invocation to be made for the courts to review the claim.

[00:10:57] Speaker 03:
Yes, the president could disavow the privilege, as President Nixon did when he allowed his staff to testify in front of the Watergate Committee.

[00:11:06] Speaker 03:
But the privilege, in a sense, applies by operation of law, unless it's waived.

[00:11:16] Speaker 03:
That's Haldeman and some of the other cases.

[00:11:19] Speaker 02:
Then it's not subpoena specific.

[00:11:22] Speaker 02:
You're just saying there's a categorical blanket.

[00:11:26] Speaker 02:
immunity.

[00:11:27] Speaker 02:
Well, a privilege, privilege slash immunity, both of them.

[00:11:31] Speaker 02:
That just exists at all times in all places, and it doesn't have to be invoked.

[00:11:35] Speaker 02:
That seems to be contradict your position before the district court and that you just reaffirmed to me.

[00:11:39] Speaker 02:
So, which is, I mean, you're bound by what you did in district court, right?

[00:11:44] Speaker 03:
Excuse me?

[00:11:44] Speaker 02:
You're bound by your position from district.

[00:11:46] Speaker 03:
Yes.

[00:11:47] Speaker 02:
Okay.

[00:11:47] Speaker 02:
So we're dealing now with a privilege belongs to the president to invoke or not and has to be invoked on a subpoena specific.

[00:11:57] Speaker 02:
I mean, that's the event here.

[00:11:58] Speaker 02:
There could be other events, but here is a subpoena specific.

[00:12:00] Speaker 03:
And what we have to rely on.

[00:12:03] Speaker 02:
So he got an email from the committee.

[00:12:06] Speaker 02:
I forget the exact time that said, hello, we're going to be shortly sending you a subpoena telling him what it was about.

[00:12:14] Speaker 02:
And three minutes later,

[00:12:17] Speaker 02:
He replied, OK, no counsel, executive privilege.

[00:12:23] Speaker 02:
Did he talk to the president?

[00:12:24] Speaker 02:
Is there any evidence in the record that he talked to the president in those three minutes?

[00:12:28] Speaker 03:
Not in those three minutes.

[00:12:29] Speaker 02:
Is there any evidence in the record that the president was alerted to the existence of this subpoena in those three minutes?

[00:12:36] Speaker 03:
Not that's in the record.

[00:12:38] Speaker ?:
OK.

[00:12:39] Speaker 02:
then how was he asserting executive privilege on a subpoena specific basis?

[00:12:45] Speaker 02:
Presumptively.

[00:12:46] Speaker 02:
Not you just said.

[00:12:47] Speaker 02:
We just went through this.

[00:12:48] Speaker 02:
There's no presumption.

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It's the president's decision to make or not.

[00:12:53] Speaker 02:
You agreed with that.

[00:12:54] Speaker 02:
You agreed that it has to be subpoena specific.

[00:12:58] Speaker 02:
I can't say that.

[00:13:00] Speaker 02:
And he invoked it without having talked to the president.

[00:13:04] Speaker 02:
Did he talk to anybody?

[00:13:05] Speaker 02:
Is there anything in the record that shows he talked to anybody before he sent back that response?

[00:13:10] Speaker 03:
No, what's in the record is the prevailing claims of privilege that were floating around the White House at the time.

[00:13:17] Speaker 02:
Yeah, that's fine.

[00:13:18] Speaker 02:
That's extraordinary.

[00:13:20] Speaker 02:
One wasn't made here.

[00:13:21] Speaker 02:
I mean, one was made for him for another committee.

[00:13:24] Speaker 02:
They were expressly made.

[00:13:24] Speaker 02:
We didn't have this issue in these other cases.

[00:13:26] Speaker 02:
They were expressly made for others.

[00:13:29] Speaker 02:
And it's almost the silence that speaks volumes.

[00:13:33] Speaker 02:
It wasn't here.

[00:13:33] Speaker 02:
But I'm coming back to he asserted executive privilege, which is not his to assert.

[00:13:38] Speaker 02:
The president gets to assert it.

[00:13:40] Speaker 02:
He can communicate it after the president does.

[00:13:43] Speaker 02:
But it has to be subpoena specific.

[00:13:46] Speaker 03:
The only thing in addition that's in the record is the Justin Clark testimony in the grand jury, which suggested that Peter Navarro didn't need a letter because he had his own direct line of communication with the president.

[00:14:02] Speaker 02:
Which he didn't use before invoking executive privilege.

[00:14:05] Speaker 03:
Which he used later.

[00:14:07] Speaker 02:
Well, then he had no business to invoke it.

[00:14:09] Speaker 02:
But if he used it later, we don't have any.

[00:14:12] Speaker 02:
I mean, this was his opportunity at the hearing

[00:14:16] Speaker 02:
to make a record of, I contacted the president or whomever on X date.

[00:14:22] Speaker 02:
And this is specifically what the president said.

[00:14:25] Speaker 02:
And it's just amazing the ambiguities that are there.

[00:14:28] Speaker 02:
It's very, very vague.

[00:14:34] Speaker 02:
Do you have a case where a claim of privilege

[00:14:40] Speaker 02:
with this level of vagueness, lack of specificity of executive privilege has been recognized?

[00:14:46] Speaker 02:
What's your best case?

[00:14:48] Speaker 02:
Every other one I'm aware of, you got president saying it or a piece of paper from the White House.

[00:14:56] Speaker 02:
We know the president has invoked it.

[00:14:59] Speaker 02:
I mean, it's scary for courts to think that we're going to say, oh, he must have meant for executive privilege to apply here.

[00:15:05] Speaker 02:
It's not ours to invoke.

[00:15:07] Speaker 02:
It's not yours.

[00:15:09] Speaker 02:
It's not Dr. Navarro's.

[00:15:11] Speaker 02:
It's the president's to invoke.

[00:15:12] Speaker 02:
And it's not for courts to say, we think he meant it, and so we'll invoke it.

[00:15:16] Speaker 02:
That's a terrible separation of powers problem that the lack of evidence in this case has put us into.

[00:15:22] Speaker 03:
Yes, if you can't accept that there's a presumptive privilege that could apply.

[00:15:29] Speaker 02:
I don't understand how you can have a presumptive privilege and agree that it's subpoena-specific, as you said, in district court.

[00:15:37] Speaker 02:
I don't know what the difference between a presumptive privilege and a blanket privilege is.

[00:15:40] Speaker 02:
Can you tell me what the difference is?

[00:15:43] Speaker 03:
Excuse me?

[00:15:43] Speaker 03:
What's the difference?

[00:15:44] Speaker 03:
Between?

[00:15:45] Speaker 02:
Blanket and presumptive.

[00:15:48] Speaker 03:
I suppose there isn't one.

[00:15:49] Speaker 02:
Well, and you disavowed blanket privilege before the district court, so neither you nor I can rely on that argument in this case.

[00:15:58] Speaker 00:
Going back to subpoena specific,

[00:16:02] Speaker 00:
How could you even say that all the documents and testimony that would have been requested would have been very specific to any official acts when we're talking about Dr. Navarro's book, his work on the 2020 campaign, his position on alleged 2020 election fraud?

[00:16:18] Speaker 00:
You know, some of these appear to be going outside of why an executive privilege would even be asserted.

[00:16:25] Speaker 03:
But again, our view was that if there was an accommodation process in which officials or the president's lawyers in the committee would consider that, they would parse that out the way they did in Myers and all that.

[00:16:42] Speaker 00:
in a trial and then they go through whether or not they're going to assert the Fifth Amendment question by question.

[00:16:48] Speaker 00:
You show up for a deposition, your attorney gets to assert certain privileges for it, you know, the client or don't answer that question.

[00:16:57] Speaker 00:
I mean, definitely question by question, circumstance by circumstance.

[00:17:02] Speaker 03:
Not in these cases, which are inter-branch cases.

[00:17:07] Speaker 00:
The accommodation process would be something that is offered ahead of time.

[00:17:13] Speaker 00:
But also if you show up, you haven't weighed the right for that to continue or for you to challenge any question or document that you don't want to speak to.

[00:17:22] Speaker 00:
So I just don't want us to think that

[00:17:25] Speaker 00:
there was some error perhaps in Congress not engaging in an accommodation process when there still was an opportunity for Dr. Navarro to speak to those issues.

[00:17:35] Speaker 03:
Right.

[00:17:35] Speaker 03:
And there were other witnesses who did not show up and did not provide documents who were not prosecuted.

[00:17:42] Speaker 00:
And that's the discretion of the DOJ in every criminal case, correct?

[00:17:47] Speaker 03:
It's the discretion, but it's the reversal or a change in position from 50 years of OLC opinions.

[00:17:58] Speaker 01:
So has anybody with as

[00:18:03] Speaker 01:
little to show for his assertion that the president had invoked executive privilege.

[00:18:14] Speaker 01:
Has anybody in that situation with analogous

[00:18:18] Speaker 01:
tea leaves about the invocation of executive privilege, has anybody in that situation failed to produce any log of basis for the privilege applying to documents responsive to the subpoena, failed to show up with no notice, and not been prosecuted?

[00:18:45] Speaker 03:
Only Mr. Scavino.

[00:18:48] Speaker 01:
I thought Scavino had some more of an assertion by the president now.

[00:18:53] Speaker 01:
I thought you argued that in your brief.

[00:18:54] Speaker 03:
He had a lawyer's letter.

[00:18:56] Speaker 03:
From what lawyer?

[00:18:57] Speaker 03:
A Trump lawyer.

[00:19:01] Speaker 01:
At the time, not a post hoc letter.

[00:19:03] Speaker 03:
I believe it was before.

[00:19:06] Speaker 01:
And that's the closest that you have.

[00:19:07] Speaker 01:
Anything else close?

[00:19:11] Speaker 03:
Mark Meadows provided initially some documents and then

[00:19:18] Speaker 03:
declined to provide further documents or go to the deposition.

[00:19:22] Speaker 03:
And he was referred for contempt, and the US attorney declined prosecution.

[00:19:28] Speaker 02:
You had an express invocation by the president there, did you not?

[00:19:31] Speaker 03:
Yes.

[00:19:35] Speaker 01:
So the other thing that's historic, in addition to what you said, which is here's somebody who served close to the president and was

[00:19:46] Speaker 01:
charged with contempt and convicted, it's also historic in the sense that you don't have someone who did what Dr. Navarro did, that you can point to historically.

[00:19:56] Speaker 03:
Not in my personal archives.

[00:20:01] Speaker 01:
You studied the materials, yeah.

[00:20:05] Speaker 01:
I was just interested in the relationship between your failure to accommodate argument and your argument that the privilege is adequately asserted.

[00:20:21] Speaker 01:
Are you saying that even if no privilege were adequately asserted, that that's sort of not right because there was a failure?

[00:20:32] Speaker 01:
of accommodation, so you see that as an independent ground?

[00:20:38] Speaker 03:
Yes, I would accept that.

[00:20:41] Speaker 01:
So even if there were no privilege or immunity available to Dr. Navarro, you would say he should, we should reverse the conviction or vacate the conviction because Congress violated its constitutional duty of accommodation?

[00:20:59] Speaker 01:
And what is that?

[00:21:00] Speaker 01:
What would spell out what you envision the committee?

[00:21:05] Speaker 01:
was required, constitutionally required to do that it didn't do.

[00:21:08] Speaker 03:
Well, I guess at a minimum to contact the president's lawyers and begin the process, as happened in Myers and Holder.

[00:21:15] Speaker 02:
Why doesn't he have to contact the White House first to see if there's going to be a claim of privilege?

[00:21:19] Speaker 02:
I don't understand.

[00:21:20] Speaker 02:
Well, he's not a lawyer.

[00:21:21] Speaker 02:
I don't understand.

[00:21:23] Speaker 02:
He's a close presidential adviser at a time when this is going on right and left.

[00:21:27] Speaker 02:
And apparently, he was supposed to know about this presumptive privilege as a non-lawyer than I should think he would know.

[00:21:32] Speaker 02:
to contact the White House before asserting executive privilege.

[00:21:39] Speaker 02:
You can't answer that.

[00:21:43] Speaker 02:
If the email and then subpoena from the committee had said, we want to talk to you about your Post Service and the Administration book and your public statements about the book, that is all we wish to talk to you about.

[00:22:03] Speaker 02:
What happens then?

[00:22:04] Speaker 03:
That certainly would have narrowed.

[00:22:05] Speaker 02:
I'm aware of what my question is doing on the facts.

[00:22:09] Speaker 02:
I'm asking you what the legal position is.

[00:22:11] Speaker 02:
Your legal position is?

[00:22:14] Speaker 03:
I think that would have been a more properly cabined request.

[00:22:22] Speaker 02:
What is your position on?

[00:22:24] Speaker 02:
OK, now I'm going to try this again.

[00:22:27] Speaker 02:
I've described to you what the request is and his response is,

[00:22:31] Speaker 02:
executive privilege.

[00:22:33] Speaker 02:
Yes or no?

[00:22:34] Speaker 02:
Is he right or wrong?

[00:22:35] Speaker 02:
It's non-lawyer to have said that.

[00:22:38] Speaker 03:
As to the document request or as to both?

[00:22:41] Speaker 03:
Both.

[00:22:42] Speaker 03:
Well, you can answer one at a time.

[00:22:44] Speaker 03:
As to the testimony, I think that would still present the problem outlined in the OLC opinion of showing up and having... The OLC opinion did not address the situation at all.

[00:22:55] Speaker 02:
The OLC opinion did not address this scenario at all.

[00:22:59] Speaker 02:
Public statements

[00:23:01] Speaker 02:
public discussions in a book by someone who is out of office.

[00:23:06] Speaker 02:
There is a president who is out of office.

[00:23:08] Speaker 02:
Right.

[00:23:10] Speaker 02:
So we'll see, it's not going to help you here.

[00:23:11] Speaker 03:
There is still in re ESPY, which held that a presidential press statement about the matters that the independent council was seeking to subpoena was not a waiver.

[00:23:27] Speaker 02:
So there's that.

[00:23:29] Speaker 02:
I'm not arguing about waivers here.

[00:23:31] Speaker 02:
This is not a waiver case.

[00:23:32] Speaker 02:
I'm asking you whether there's any argument for either just to avoid the labels, documentary privilege and showing up, the testimonial privilege, showing up privilege.

[00:23:48] Speaker 02:
Either one?

[00:23:52] Speaker 02:
And he didn't, when they said, we also want to talk to you about these things like your book, he did not, I take it he agreed with you, you agree with where he was.

[00:24:01] Speaker 02:
He did not at that point say executive privilege.

[00:24:04] Speaker 03:
I didn't, I didn't represent him during that period, but yes.

[00:24:07] Speaker 02:
Well, you're aware of the record.

[00:24:08] Speaker 03:
Yes.

[00:24:09] Speaker 02:
Yeah.

[00:24:09] Speaker 02:
Okay.

[00:24:09] Speaker 02:
So he didn't never sort of executive privilege or testimony of the privilege as to that aspect or just back and forth on different things it seemed like.

[00:24:20] Speaker 03:
I see my time is up.

[00:24:21] Speaker 02:
Any questions?

[00:24:23] Speaker 02:
Thank you.

[00:24:25] Speaker 02:
No, thanks.

[00:24:32] Speaker 02:
Thank you.

[00:24:33] Speaker 02:
Thank you very much for coming this afternoon.

[00:24:36] Speaker 02:
Normally I would offer you rebuttal, but there's nothing to rebut.

[00:24:40] Speaker 03:
Yes, it's been a very strange journey on that front.

[00:24:44] Speaker 02:
Thank you.

[00:24:45] Speaker 02:
The case is submitted.