DPLA Home The Impeachment Papers A Compendium of Documents Related to the Impeachment of President Donald J. Trump
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Giuliani Lawyer Response to Congressional Subpoena

A logo: Nelson Mullins Broad and Cassel.
Jon A. Sale, Of Counsel and Co-Chair White
Collar & Government Investigations Practice Group
Direct Line: 305.373.9454

One Biscayne Tower
2 South Biscayne Blvd. | 21st Floor
Miami, FL 33131
T: 305.373.9400 F: 305.373.9443
*In Florida, known as Nelson Mullins Broad and Cassel

October 15, 2019


Nicolas A. Mitchell
Investigation Counsel
House Permanent Select Committee on Intelligence Congress
Washington, D.C. 20515

Dear Mr. Mitchell:

I am writing on behalf of Mr. Rudolph W. Giuliani in response to the letter from Chairmen Schiff, Engel, and Cummings dated September 30, 2019, and the accompanying subpoena. Please accept this response as formal notice that Mr. Giuliani will not participate because this appears to be an unconstitutional, baseless, and illegitimate “impeachment inquiry.” By way of this response, Mr. Giuliani adopts all the positions set forth in Mr. Cipollone’s October 8, 2019 letter on behalf of President Donald J. Trump.

In addition, the subpoena is overbroad, unduly burdensome, and seeks documents beyond the scope of legitimate inquiry. Moreover, documents sought in the subpoena are protected by attorney-client, attorney work-product, and executive privileges.


A signature: Jon A. Sale.

Jon A. Sale

Counsel for Rudolph W. Giuliani