A —which was also the—
Q —email—
A —attached exhibit.
Q I am sorry. Go ahead. I didn't mean to interrupt you.
A It's dated May 11th, 2009, and it was attached to the email that I sent out.
Q Okay. So, on November 11th, you sent the White House contacts policy out to all the Assistant Attorneys General?
A A Correct. It looks like it also sent out the White House version of this as well. They have a parallel policy.
Q Okay. Why, Mr. Donoghue, did you send that out to the field or to the AAGs November 11th, like a week or so after the election?
A I sent this out pursuant to a discussion I'd had earlier that day with Will Levi, L-e-v-i. Will was AG Barr's chief of staff at that point. I don't remember the specifics, but I remember Will saying that he had sent this out to people on the AG's staff, and he thought it might be prudent to send it out to the AAGs.
We were in the post-election period. You know, there was a tremendous amount of churn in terms of election fraud allegations. And, I forget exactly what Will said, but he said something to the effect of "let's make sure people are aware of the policies and remind them of the policies so that no one stumbles over a line," something to that effect.
Q Was there concern, in your view, that people without warning might stumble over the policy by getting outreach from the White House?
A I didn't have that concern with regard to the AAGs certainly. But, again, Will suggested I send it out. There was no harm in doing so. I thought it was prudent, so I just sent it out.
