Page:Impeachment of Donald J. Trump, President of the United States — Report of the Committee on the Judiciary, House of Representatives.pdf/128

 would like you to do us a favor though[.]" President Trump then explained the "favor," which involved the two demands for baseless investigations. In addition, the July 25 call "was neither the start nor the end" of these demands. In the weeks leading up to it, for example, Ambassadors Volker and Sondland had both personally informed President Zelensky and his staff of the President's demands and advised the Ukrainian leader to agree to them. These and other related actions by the President's subordinates were taken in coordination with Rudolph Giuliani, who was understood to be "expressing the desires of the President of the United States." There can thus be no doubt that President Trump's conduct constituted a solicitation.

ii."Anything of Value Personally"

The next question is whether any of the "things" that President Trump solicited from President Zelensky count as a "things of value." Section 201 makes clear that bribery occurs when the thing offered or solicited is "anything of value personally" to the recipient —and in this instance, President Trump placed significant personal value on the "favor[s]" demanded.

"The phrase 'anything of value' has been interpreted broadly to carry out the congressional purpose of punishing the abuse of public office." It "is defined broadly to include 'the value which the defendant subjectively attaches to the items received.'" For example, it has been held to include shares of stock that had "no commercial value" where the official receiving the bribe expected otherwise. As the court in that case explained, "[c]orruption of office occurs when the officeholder agrees to misuse his office in the expectation of gain, whether or not he has correctly assessed the worth of the bribe." The term "thing of value" encompasses intangible things of value as well. As used throughout the criminal code, it has been held to include (among other things): research work