68
month that President Trump was elected.
417
In the week after election night, FBI Agent Peter
Strzok and FBI lawyer Lisa Page—who were both involved in the Russia collusion
investigation—wrote to each other: “OMG THIS IS F*CKING TERRIFYING” and “I bought all
the president’s men. Figure I needed to brush up on watergate [sic].”
418
The FBI surveilled Trump campaign associates using evidence delivered by Christopher
Steele—a confidential human source funded by then-candidate Trump’s political opponents and
who admitted he was “desperate” that Donald Trump lose the election.
419
During her deposition,
Dr. Hill testified that Steele’s reporting was likely a bogus Russia misinformation campaign
against Steele.
420
Yet, the FBI accepted Steele’s information and used it to obtain surveillance
warrants on Trump campaign associate Carter Page.
421
Ultimately, Special Counsel Mueller’s
report concluded that the Trump campaign did not conspire or coordinate with Russian election
interference actions.
422
In considering the President’s mindset, this context cannot be ignored.
3. The President has the constitutional authority to remove Ambassador
Yovanovitch.
U.S. ambassadors are the President’s representatives abroad, serving at the pleasure of
the President. Every ambassador interviewed during this impeachment inquiry recognized and
appreciated this fact.
423
Even Ambassador Yovanovitch understood that the President could
remove any ambassador at any time for any reason, although she unsurprisingly disagreed with
the reason for her removal.
424
The removal of Ambassador Yovanovitch, therefore, is not per se
evidence of wrongdoing for the President’s political benefit.
Evidence suggests that President Trump likely had concerns about Ambassador
Yovanovitch’s ability to represent him in Ukraine,
425
and that then-Ukrainian President
417
Inspector Gen., Dep’t of Justice, A Review of Various Actions by the Federal Bureau of Investigation and
Department of Justice in Advance of the 2016 Election, 396, 419 (2018).
418
Id. at 397, 400.
419
F.B.I., Dep’t of Just., 302 Interview with Bruce Ohr on Dec. 19, 2016 at 3.
420
See Hill deposition, supra note 12, at 177-180 (“I think it was a rabbit hole . . . . The way that the Russians
operate is that they will use whatever conduit they can to put out information that is both real and credible but that
also masks a great deal of disinformation . . . .”).
421
Transcribed Interview of Sally Moyer, in Wash., D.C., at 162 (Oct. 23, 2018).
422
Mueller report, supra note 416.
423
Sondland deposition, supra note 51, at 19; Volker transcribed interview, supra note 60, at 88-89; Transcribed
interview of Ambassador Michael McKinley, in Wash., D.C., at 37 (Oct. 16, 2019) [hereinafter “McKinley
transcribed interview”]; Yovanovitch deposition, supra note 115, at 23; Taylor deposition, supra note 47, at 297;
Hale deposition, supra note 230, at 38.
424
Yovanovitch deposition, supra note 115, at 23. Evidence suggests that Ambassador Yovanovitch took steps to
gain the President’s trust. Deputy Assistant Secretary of State George Kent testified that Ambassador Yovanovitch
taped videos in which she proclaimed support for the Trump Administration’s foreign policies. Kent deposition,
supra note 65, at 118-19. Ambassador Yovanovitch testified that she sought Ambassador Sondland’s guidance on
how to address negative news reports critical of her work as Ambassador to Ukraine. She said that Ambassador
Sondland told her to “go big or go home” in publicly supporting the President. Yovanovitch deposition, supra note
115, at 267-28, 306-07. Ambassador Sondland, however, testified that he did not recall advising Ambassador
Yovanovitch to make a public statement. Sondland deposition, supra note 51, at 58-59.
425
Memorandum of Telephone Conversation, supra note 15.