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 25 See House Committee on the Judiciary, Impeachment of Richard M. Nixon, President of the United States, 93rd Cong. (1974) (H. Rep. 93-1305).

26 Id.

27 Id. (quoting letter from Chairman Peter W. Rodino, Jr., House Committee on the Judiciary, to President Richard M. Nixon (May 30, 1974)).

28 H.R. Jour., 29th Cong., 1st Sess., 693 (Apr. 20, 1846).

29 Senate Select Committee on Secret Military Assistance to Iran and the Nicaraguan Opposition and House Select Committee to Investigate Covert Arms Transactions with Iran, Testimony of Oliver North, Iran-Contra Investigation: Joint Hearings Before the House Select Committee to Investigate Covert Arms Transactions with Iran and the Senate Select Committee on Secret Military Assistance to Iran and the Nicaraguan Oppositions, 100th Cong. (July 7, 1987); Senate Select Committee on Secret Military Assistance to Iran and the Nicaraguan Opposition and House Select Committee to Investigate Covert Arms Transactions with Iran, Testimony of John Poindexter, Iran-Contra Investigation: Joint Hearings Before the House Select Committee to Investigate Covert Arms Transactions with Iran and the Senate Select Committee on Secret Military Assistance to Iran and the Nicaraguan Oppositions, 100th Cong. (July 15, 1987).

30 Committee on the Judiciary v. McGahn, Civ. No. 1:19-cv-02379, Memorandum Opinion, Doc. No. 46 (D.D.C. Nov. 25, 2019). As of this report, an appeal is pending in the D.C. Circuit. No. 19-5331 (D.C. Cir.).

31 Committee on Government Reform, Democratic Staff, Congressional Oversight of the Clinton Administration (Jan. 17, 2006) (online at https://wayback.archive-it.org/4949/20141031200116/http://oversightarchive.waxman house.gov/documents/20060117103516-91336.pdf) (noting that Republican Dan Burton, Chairman of the Committee on Government Reform, deposed 141 Clinton Administration officials during his tenure).

32 Select Committee on the Events Surrounding the 2012 Terrorist Attack in Benghazi, Final Report of the Select Committee on the Events Surrounding the 2012 Terrorist Attack in Benghazi, 114th Cong. (2016) (H. Rep. 114-848) (noting that the Select Committee interviewed or received testimony from 107 people—none of whom was instructed not to appear—including 57 current and former State Department officials such as Secretary of State Hillary Clinton, Chief of Staff and Counselor to the Secretary of State Cheryl Mills, Deputy Chief of Staff and Director of Policy Planning Jacob Sullivan, and Deputy Chief of Staff for Operations Huma Abedin; 24 Defense Department officials such as Secretary Leon Panetta and General Carter Ham; and 19 Central Intelligence Agency (CIA) officials such as Director David Petraeus and former Deputy Director Michael Morell).

33 Id. (including productions of 71,640 pages of State Department documents, 300 pages of CIA intelligence analyses, 200 pages of Federal Bureau of Investigation (FBI) documents, 900 pages of Defense Department documents, and 750 pages of National Security Agency documents).

34 See, e.g., House rule X, clause 2(a) (assigning "general oversight responsibilities" to committees); House Rule XI, clause 2(m) (authorizing Committees to "hold such hearings as it considers necessary" and to "require, by subpoena or otherwise, the attendance and testimony of such witnesses and the production of such books, records, correspondence, memoranda, papers, and documents as it considers necessary"); H. Res. 6 (2019) (granting deposition authority to committees); 116th Congress Regulations for Use of Deposition Authority, Congressional Record (Jan. 25, 2019) (establishing procedures for committee depositions).

35 See, e.g., House Rules (2017); H. Res. 5 (2017); 115th Congress Staff Deposition Authority Procedures, Congressional Record (Jan. 13, 2017).

36 Special Counsel Robert S. Mueller III, Department of Justice, Report on The Investigation Into Russian Interference In The 2016 Presidential Election, Vol. I (March 2019) (online at www.justice.gov/storage/report.pdf); Special Counsel Robert S. Mueller, III, Department of Justice, Report on The Investigation Into Russian Interference In The 2016 Presidential Election, Vol. II (March 2019) (online at www.justice.gov/storage/report_volume2.pdf).

37 See H. Res. 430; see also H. Rep. 116-105 (2019) (the purposes of the Judiciary Committee's investigation include "considering whether any of the conduct described in the Special Counsel's Report warrants the Committee in taking any further steps under Congress' Article I powers," including "whether to approve articles of impeachment with respect to the President or any other Administration official"). 263