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House Oversight — Estate records

HOUSE_OVERSIGHT_031670

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COVINGTON 
BEIJING BRUSSELS LONDON LOS ANGELES 
NEW YORK SAN FRANCISCO SEOUL 
SHANGHAI SILICON VALLEY WASHINGTON 
By E-Mail and First Class Mail 
The Honorable Richard Burr 
The Honorable Mark R. Warner 
Select Committee on Intelligence 
United States Senate 
Washington, D.C. 20510 
Robert K. Kelner 
Covington & Burling LLP 
One CityCenter 
850 Tenth Street, NW 
Washington, DC 20001-4956 
May 22, 2017 
Re: Subpoena to Lieutenant General Michael T. Flynn (Ret.) 
Dear Chairman Burr and Vice Chairman Warner: 
We write in response to the Senate Select Committee on Intelligence's subpoena dated 
May 10, 2017, requesting that our client, Lieutenant General Michael T. Flynn (Ret.), produce 
any documents he may have that are responsive to a broad range of requests covering an 18-
month period of time. Specifically, the subpoena requests that he create a list of all meetings and 
all communications between himself and Russian officials, and that he produce records of all 
communications between himself and President Trump's campaign that were in any way related 
to Russia, for the period from June 16, 2015, to January 20, 2017. 
In our May 8, 2017, letter to the Committee, we reiterated General Flynn's eagerness to 
give a full account of the facts and to answer the Committee's questions, should the 
circumstances permit, including assurances against unfair prosecution. We stated that, absent 
such assurances, General Flynn would respectfully decline your request for an interview and for 
the production of documents. 
Our client's position remains unchanged. Producing documents that fall within the 
subpoena's broad scope would be a testimonial act, insofar as it would confirm or deny the 
existence of such documents. Under the Fifth Amendment to the United States Constitution and 
applicable court precedents, no person is required to offer testimony when he has "reasonable 
cause to apprehend danger from a direct answer," even when that person is entirely innocent 
and has

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