Page:Impeachment of Donald J. Trump, President of the United States — Report of the Committee on the Judiciary, House of Representatives.pdf/154

 President for Domestic Affairs John D. Ehrlichman. President Nixon also produced numerous documents and records in response to Congressional subpoenas, including more than 30 transcripts of White House recordings and notes from meetings with the President. This was consistent with prior practice. As the Judiciary Committee explained at the time: "Before the current inquiry, sixty-nine Federal officials had been the subject of impeachment investigations. With the possible exception of one minor official who invoked the privilege against self-incrimination, not one of them challenged the power of the committee conducting the investigation to compel the production of evidence it deemed necessary."

However, President Nixon's production of records was incomplete in a very important respect: he did not produce key tape recordings of Oval Office conversations, and some of the transcripts of such recordings that he produced were heavily edited or inaccurate. President Nixon claimed that his noncompliance with House subpoenas was necessary to protect the confidentiality of Presidential conversations. But as we explain further in the next section, this Committee rejected his arguments and approved an article of impeachment against President Nixon for obstruction of the House's impeachment inquiry.

Twenty-four years later, the House undertook impeachment proceedings against President Clinton. Consistent with precedent, he "pledged to cooperate fully with the [impeachment] investigation." And although the House engaged in very little independent fact-finding, President Clinton substantially cooperated, providing written responses to 81 interrogatories from the Judiciary Committee during the impeachment inquiry—as well as his own DNA.

Thus, Presidents have long recognized that the House enjoys a nearly plenary power of inquiry while investigating grounds for impeachment. This conclusion is further supported by an additional