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 contributions.

To be sure, after the whistleblower complaint was filed and the President became aware he had been caught, Mr. Sandy began receiving questions in September about burden sharing. But that sequence only underscores the fact that this explanation was an after-the-fact justification to cover his tracks, as the hold had been in place for nearly two months without burden-sharing provided as a reason. Moreover, after Congress began investigating President Trump's conduct, the White House Counsel's Office reportedly conducted an internal review of "hundreds of documents," which "reveal[ed] extensive efforts to generate an after-the-fact justification" for the hold on assistance for Ukraine ordered by President Trump. These documents reportedly included "early August email exchanges between acting chief of staff Mick Mulvaney and White House budget officials seeking to provide an explanation for withholding the funds after the president had already ordered a hold in mid-July on the nearly $400 million in security assistance." Given the substantial evidence of irregular conduct at OMB—including, according to Mr. Sandy, the resignation of two OMB officials partly based on their objection to OMB's handling and rationale for the hold on assistance to Ukraine —this effort to manufacture a pretext cannot reasonably be credited.

It also bears mention that European countries do, in fact, contribute substantial assistance to Ukraine. Since 2014, the European Union and European financial institutions have provided more than $16 billion in grants and loans to Ukraine, making the EU the largest donor to Ukraine. This far exceeds the approximately $1.95 billion in assistance that the United States has provided during the same period, according to USAID. Although the United States is the largest donor of military assistance to Ukraine, European countries also provide military aid to Ukraine through a NATO assistance package. For example, the United Kingdom has sent more than 1,300 soldiers to Ukraine since 2015 and has trained approximately 10,000 Ukrainian troops.

iii.Legitimate Investigations

The third and final justification that the Minority Report offers to explain President Trump's conduct is that he had a legitimate basis to request investigations into his political rival and the