We received the President’s written responses in late November 2018.4 In December 2018, we informed counsel of the insufficiency of those responses in several respects.5 We noted, among other things, that the President stated on more than 30 occasions that he “does not ‘recall’ or ‘remember’ or have an ‘independent recollection’” of information called for by the questions.6 Other answers were “incomplete or imprecise.”7 The written responses, we informed counsel, “demonstrate the inadequacy of the written format, as we have had no opportunity to ask follow-up questions that would ensure
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