Page:CTRL0000034602 - Transcribed Interview of Jeffrey Clark, (November 5, 2021).pdf/35

35 We object.

Mr. Let the record reflect that counsel has cited no particular privilege to refuse to answer that question,

So, Mr. MacDougald, I'm just looking at the letter, again, not having a chance yet to read it carefully. And, on page 2, it says, the general category of executive privilege, the specific categories of Presidential communications, law enforcement, and deliberative process privileges, as well as attorney-client privilege, and the work product doctrine, all harmonize on this point. Is that the universe of privileges that that sentence that I just read from your letter that Mr. Clark is asserting today?

Mr. Well, the—you should read the entire letter

I appreciate that, but I'm—again, not having had a chance to do that, I just want to make sure it's clear on the record.

Mr. Well, we think the letter is clear, and the letter is on the record.

At the time of these events, Mr. Clark was an employee of the Department of Justice, right, and his client was the people of the United States, not President Trump or anyone else. So help me understand how any attorney-client privilege could possibly be implicated when a Department of Justice official, a member of the executive branch, in the course of his professional responsibilities, is engaged in talking to his superiors or anyone else within the executive branch?

Mr. I will say maybe for the fifth or sixth time, we're not going to engage in legal argument on these points in the deposition. If you want to engage in legal argument in letters or court filings, we're happy to do that, but we're not going to do it in this deposition,

Yeah

Mr. And so I think we have, you know, reached an impasse and,