The Capitol Riot, Infowars, and the Definition of Journalism

Earlier this summer, Attorney General Merrick Garland announced revisions to the Department of Justice internal rules on obtaining records from journalists. With limited exceptions, the policy provides that DOJ will not subpoena information from members of the “news media” who were engaged in “newsgathering activities.” Now a case arising from the January 6 Capitol riot has highlighted a question posed by this policy: who qualifies as a member of the news media entitled to its protections? More specifically: is the conspiracy-touting, right-wing website Infowars engaged in journalism? The answer to this question has implications far beyond cases involving the insurrection at the Capitol.

The Owen Shroyer Case

Jonathon Owen Shroyer is the host of a daily program that streams on Infowars, “The War Room with Owen Shroyer.” Infowars is a “news service” website led by Alex Jones. Jones and Infowars are noted for promoting various conspiracy theories, including that the 2012 shooting of twenty children and six adults at Sandy Hook elementary school was faked and that a Washington, D.C. pizza parlor housed a child sex trafficking ring associated with Hillary Clinton – a conspiracy hoax that became known as “Pizzagate.” Jones, Shroyer, and Infowars have been banned from most social media sites for spreading disinformation.

Infowars was a favorite of former president Trump, who routinely praised Jones and echoed the site’s outrageous claims. Infowars also played a significant role in helping perpetuate the “big lie” that the 2020 presidential election was stolen. After Trump lost re-election, Shroyer led a nine-city tour of “Stop the Steal” rallies. He was also featured in materials published by Infowars promoting the January 6, 2021 rally in Washington and urging people to attend and “fight for Trump.”

Exhibit from the Shroyer Arrest Warrant

On January 5, Shroyer spoke at a rally at Freedom Plaza in D.C. where he said, “Americans are ready to fight! . . . We are the new revolution!” Video footage allegedly shows him taking part in marching to the Capitol on January 6, exhorting the mob to stop the election from being “stolen,” and leading the crowd in a chant of “1776!” At one point during the rally, he called live into an Infowars broadcast and reported, “They’ve taken the Capitol grounds, they’ve surrounded the building itself, they’re on the actual building structure. . . . We literally own these streets right now.”

Last week, Shroyer was arrested for his role in the Capitol riot and appeared in court in Washington, D.C. Prosecutors have charged him with entering a restricted area of the Capitol and with unlawfully attempting to impede the work of Congress. Both offenses are misdemeanors. It appears he will maintain that he was covering the events in Washington as a journalist for Infowars.

The Judge’s Inquiry

On August 19, U.S. Magistrate Judge Zia Faruqui held a telephone conference with prosecutors regarding the arrest warrant for Shroyer. Faruqui asked prosecutors whether they considered Shroyer a member of the news media and whether they had complied with the new DOJ media regulations when investigating him. Prosecutors said they had followed the guidelines, but declined to provide specifics. This caused Faruqui to issue an opinion a few days later, expressing his displeasure. He claimed that prosecutors in other cases have provided more details about their compliance with the regulations, and it troubled him they did not do so here: “The Department of Justice appears to believe that it is the sole enforcer of its regulations. That leaves the court to wonder who watches the watchmen.”

Faruqui’s opinion is a little odd, in that it doesn’t order the prosecutors to do anything. He ultimately signed the arrest warrant, concluding that even if Shroyer was a journalist there was ample evidence that he committed a crime. It appears Faruqui just wanted to make a clear record of his request and of his concerns about whether DOJ was in fact following its own media guidelines.

In a letter to the court, John Crabb, Jr., Chief of the Criminal Division at the U.S. Attorney’s Office, responded with the polite legal equivalent of, “Buzz off.” Crabb wrote that enforcing internal regulations like the media guidelines is committed to DOJ’s sole discretion. It is not the court’s role, he argued, to police DOJ’s application of internal policies that have nothing to do with the finding of probable cause. He also argued that such inquiries by the court might impede “frank and thoughtful deliberations within the Department” about how to apply the regulations.

Crabb is clearly right here, and Faruqui was out of line. The DOJ “Justice Manual” contains many policies about how to interpret and enforce certain areas of the law. Department attorneys may be subject to internal discipline for failing to follow those policies. But it is well-established that those policies do not create rights that may be enforced by outside parties. These are voluntary internal operating rules, not laws passed by Congress.

If Shroyer believes he has some kind of First Amendment defense based on his alleged status as a journalist, he can file a motion and the judge can rule on it. But under the separation of powers, it’s not Faruqui’s role to probe DOJ’s application of its own voluntary policies that have nothing to do with the legal merits of the case. At some level Faruqui himself seems to recognize this, since he issued his opinion but did not require DOJ to do anything in response.

US Dept of Justice
U.S. Department of Justice

DOJ’s Media Guidelines

As noted above, Faruqui’s inquiry was based on DOJ’s recently-modified guidelines about subpoenas to members of the media. Those guidelines have been around in various forms for decades. They represent the Department’s effort to balance the needs of law enforcement with the important First Amendment interests of the news media in gathering information without fear of government interference or punishment.

Journalists have long argued that they should have a legal privilege to refuse government demands for information about their reporting and sources. They claim such a privilege is necessary to protect the vital role of the free press in rooting out government misconduct. They argue that, absent such a privilege, government leakers and other sources of information who may fear reprisals if discovered will refuse to speak to reporters. Just as communications to lawyers and doctors are shielded from disclosure by the legal system, they argue, communications to journalists should be protected in order to ensure the free flow of information to the public.

[Side note: I think the arguments for the reporter’s privilege are wrong and that the privilege is a bad idea. I’ve written a lot on that topic – including in the very first post on this blog. Those arguments are beyond my scope here, but if you are interested in a deeper dive you can check out my blog posts here, here, and here, and law review articles here and here.]

In the landmark 1972 case of Branzburg v. Hayes, the Supreme Court held that the First Amendment does not create a privilege that allows journalists to refuse to testify, at least in federal criminal proceedings. In the aftermath of Branzburg, DOJ adopted its media guidelines, recognizing that even if the Constitution did not require it, DOJ should recognize the First Amendment interests at stake and exercise its discretion not to pursue information from journalists in most cases.

Battles Over the Reporter’s Privilege

There have been a few high-profile fights between DOJ and journalists who resisted complying with court orders to reveal information about their sources, although overall such cases are quite rare. Perhaps the most notable example involved New York Times reporter Judith Miller, who was jailed for nearly three months in 2005 when she refused to reveal her source to a grand jury investigating the leak of a CIA agent’s identity. (Vice president Dick Cheney’s chief of staff, Scooter Libby, was ultimately convicted of perjury and obstruction of justice in that investigation. Libby was pardoned by president Trump in 2018.)

Another dispute involved yet another New York Times reporter, James Risen, who refused to reveal his source for a story that revealed classified information about a covert U.S. government operation in Iran. Risen took his fight all the way to the U.S. Supreme Court, and the courts ruled he had no privilege and could be compelled to testify. Risen made it clear that he, like Miller, would go to jail rather than comply. The government ultimately backed down, chose not to call him as a witness, and managed to convict the source, Jeffrey Sterling, without Risen’s testimony.

During the Obama administration, the Justice Department under Attorney General Eric Holder was strongly criticized by media organizations for its pursuit of those who leaked classified information to the press. Obama’s DOJ was accused of engaging in a “war on the press” — a ridiculous charge, as I explained here. Nevertheless, responding to that criticism, Holder held meetings with media representatives and updated the DOJ guidelines to make it even more difficult for prosecutors to subpoena information from journalists. In general, such information could be sought only when it was vitally important to the case, when alternative avenues to obtain the information had been exhausted, and when the request was approved by high level DOJ officials.

Early in the Biden administration, DOJ disclosed that Trump’s Justice Department had secretly sought email and phone records of several reporters at the Washington Post, New York Times, and CNN, in connection with investigations of leaks of classified material. When asked about the disclosures, Biden said that seeking such records from journalists was “simply wrong” and that he would not allow it in his administration.

As a result, last July 19, as noted above, Garland issued a memo saying the media guidelines would be amended again and would now contain a flat prohibition on the use of compulsory process to seek information from members of the news media who were engaged in newsgathering activities. (There are still some limited exceptions, such as when the journalist himself is under investigation for committing a crime, is an agent of a foreign power, or when disclosure is necessary to prevent imminent risk of death or serious bodily harm.) These are the updated guidelines about which Judge Faruqui was inquiring in the Shroyer case.

Is Shroyer a Journalist?

The DOJ media guidelines have been around for decades but have never defined who qualifies as a journalist under those guidelines. The governing regulations associated with those guidelines provide that whether someone is a member of the “news media” engaged in “newsgathering activities” must be determined on a case-by-case basis – but provide no guidance on how to make that determination. So is Infowars engaged in journalism, and is Shroyer a journalist?

Unlike professions such as law or medicine, which also enjoy certain legal privileges, there are no particular educational or licensing requirements to help define who is a journalist. In one sense, journalism is more of a process than a profession. Merriam-Webster defines journalism as “the collection and editing of news for presentation to the public.”  This could include anyone from a reporter for a national newspaper to a pajama-clad blogger working from home. The First Amendment’s protections apply equally to all such speakers and do not depend on the popularity of the views being expressed.

Fifty years ago, when media consisted primarily of newspapers, magazines, and the three major television networks, the Supreme Court observed that attempting to define who is a journalist for purposes of a legal privilege would be a “questionable procedure” that would “present practical and conceptual difficulties of a high order.” The rise of the Internet and the explosive growth of the media universe in the decades since have made that task exponentially more difficult. Now anyone with a cell phone can potentially disseminate information to millions of people and claim to be engaged in citizen journalism.

For years, efforts to enact a federal reporter’s privilege statute in Congress have foundered, at least in part, over the problem of defining who is a “journalist” entitled to invoke the privilege. Any such definition necessarily puts the government in a position of deciding which First Amendment speakers are “real” journalists deserving of special legal protections – a dubious Constitutional exercise. Even some in the media have opposed the idea, arguing that it amounts to allowing the government to license journalists.

One proposed solution is to limit the definition of journalists to those who make a substantial portion of their livelihood by gathering and disseminating news to the public. But that has problems as well. Such a definition tends to favor large, established media organizations and their staff over small, independent bloggers and other upstarts who may work for little or no money but often break major stories. And if the purpose of a privilege is to increase the flow of information to the public, it doesn’t make much sense to shield the communications of a reporter for a small local paper with a few hundred readers but not those of an independent blogger with a readership in the millions.

Shroyer allegedly participated in the riot, but at the same time was broadcasting information concerning what was happening to Infowars’ substantial audience. That portion of his activities, at least, would seem to qualify as journalism. But if Shroyer broadcasting live scenes from the Capitol qualifies, how about an individual blogger who attended and posted scenes on Facebook live or on her own blog? That person, too, is providing information to the public – the essence of journalism. Should the blogger also be shielded from investigation by the DOJ policy? Should subpoenaing the Facebook posts to further the investigation of the riot now be off-limits?

Lawyers love “slippery slope” arguments, and sometimes the dilemmas they pose are overstated. But defining who qualifies as a journalist and who doesn’t is a real problem with significant constitutional implications – at least if you are talking about granting special legal privileges to journalists that other First Amendment speakers do not enjoy.

What’s At Stake

Journalists can’t commit crimes in the course of reporting and claim they are immune. A reporter cannot, for example, break into someone’s office to steal documents and then defend herself by claiming she were working on a story. Whether or not Shroyer is a journalist is not going to determine whether he can be prosecuted. Judge Faruqui recognized that when he signed the arrest warrant even while questioning whether Shroyer was a member of the media. But Shroyer’s case does highlight the minefields for law enforcement in this area.

In the Internet age, the number of people who can credibly call themselves journalists, or say they are engaged in gathering news for delivery to the public, has grown dramatically. A policy that declares the records of any such person to be off limits has the potential to put a great deal of information outside the reach of law enforcement. That could severely hamper efforts to investigate not only major crimes like the Capitol riot but more everyday incidents as well.

It’s one thing if this is just an internal DOJ policy. That leaves the Justice Department free to investigate cases like Shroyer’s when it determines the policy does not apply – even if the occasional judge Faruqui improperly tries to look over prosecutors’ shoulders. But when announcing the updated guidelines, Garland also said DOJ would support Congressional efforts to enact a federal reporter’s privilege statute. If that happens, then a whole new generation of Internet “journalists” like Shroyer will routinely will invoke that legal privilege to resist requests for information, fight subpoenas, and seek to thwart prosecutions.

DOJ should be careful what it wishes for. By endorsing federal legislation that prohibits seeking information from all those engaged in “newsgathering,” DOJ would hand a weapon to defendants like Shroyer who seek to shield their criminal activities. Congress should think twice before putting the force of federal law behind such a weapon.

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Rudy and Barr, Back in the News

One hundred days into the Biden administration, two leading characters from the Trump years are making headlines again. Federal authorities executed search warrants at the home and office of Trump’s former attorney Rudy Giuliani, dramatically escalating the criminal investigation into his activities in Ukraine. And a federal judge harshly criticized former Attorney General William Barr and his Department of Justice for engaging in a cover-up concerning Barr’s handling of the Mueller report. The stories were an unwelcome reminder of the abuses that routinely took place during the Trump years, and highlighted that we still have a lot to learn about those abuses.

Rudy Giuliani

The Giuliani Investigation

We’ve known for some time that Rudy Giuliani is the subject of a criminal investigation by the U.S. Attorney’s Office for the Southern District of New York related to his dealings with Ukraine. Those activities are closely related to the events that led to Trump’s first impeachment, when Trump asked the president of Ukraine to “do us a favor” by providing dirt on Joe Biden’s son in exchange for U.S. assistance. In 2019 Giuliani was actively working in Ukraine to to dig up potentially damaging information concerning Biden, who was considered to be Trump’s most likely rival in the 2020 election.

Giuliani also was actively involved in the successful efforts to have Trump oust the U.S. ambassador to Ukraine, Marie Yovanovitch, who was notoriously tough on government corruption. Giuliani apparently saw Yovanovitch as an obstacle to his efforts. Her ouster was also a focus of Trump’s first impeachment, and Yovanovitch testified during the House impeachment hearings about Giuliani’s smear campaign against her that ultimately led to her removal.

Prosecutors apparently are exploring whether Giuliani was working not only for Trump but also on behalf of Ukrainian government officials or other Ukrainian individuals. Those Ukrainians may have been seeking favors from the Trump administration or may have wanted the ambassador removed for their own reasons.

The Search Warrants

On April 28th, federal agents executed search warrants at Giuliani’s home and office in New York City. They reportedly seized a number of phones and electronic devices looking for communications, perhaps on encrypted apps.

According to news reports, prosecutors in the Southern District sought to execute the search warrants as early as last summer. Top DOJ officials would have needed to sign off, given the sensitivity involved in searching the office of an attorney for the president. The Barr Justice Department refused to allow it. After Merrick Garland was sworn in as Attorney General, the Justice Department gave the go-ahead.

The most charitable explanation for the Barr DOJ’s refusal to approve the warrants would be DOJ’s unwritten policy to avoid investigative steps within sixty days of an election if they might influence the vote. But if approval was sought last summer, the election was much more than sixty days away. And that policy would not explain why the searches could not have been approved after the election and before Biden’s inauguration.

Last summer was also when Barr sought to remove the U.S. Attorney for the Southern District and replace him with a Trump loyalist. All of this raises suspicions that president Trump’s Justice Department sought to protect Giuliani by stifling the investigation into his Ukraine activities as long as possible – which also, of course, protected Trump himself.

Michael Cohen

Searching an Attorney’s Office

Giuliani and his lawyers responded with predictable outrage over the search warrants. Searching an attorney’s office does raise special concerns, due to the possibility that materials covered by the attorney-client privilege might be seized. But of course a law degree does not confer immunity from the criminal law, and in appropriate circumstances attorneys may be the subject of a search warrant just like anyone else. As with any search warrant, it requires a neutral judge or magistrate to find probable cause that a crime has been committed and that evidence may be located during the search. And the Justice Department has special procedures in place to review requests for such warrants and handle the screening of potentially privileged material.

The Trump years featured another prominent example of such a search: in April 2018 investigators executed search warrants at the home and office of Michael Cohen, president Trump’s former private attorney and “fixer.” Cohen ultimately was indicted on multiple charges, pleaded guilty, and was sent to prison.

As many criminals have learned the hard way, having an attorney involved in your activities does not necessarily mean that everything the attorney touches is privileged. The attorney-client privilege applies only to communications that involve providing legal advice. If an attorney is working as a business person or in some other non-legal capacity, their activities and communications will not be shielded by the privilege. The privilege also contains an exception for communications that are made in the furtherance of a crime or fraud.

After the Cohen search, a judge appointed a special master to review all of the seized materials and screen them for anything privileged before turning them over to investigators. Ultimately only a small amount of material was withheld. Recognizing the sensitivity of these searches and hoping to speed the process along, prosecutors have already asked the court to do the same for the Giuliani materials.

It will take some time for all of the seized materials to be reviewed and we shouldn’t expect anything to happen in the immediate future. But it’s an ominous sign for Giuliani. DOJ is unlikely to take the serious step of searching an attorney’s office without a compelling reason. That’s especially true when that attorney once represented the former president of the United States. Attorney General Garland would be extremely unlikely to sign off on such politically-charged warrants if this were a marginal case.

The Potential Criminal Charges

Much of the news coverage concerning potential criminal charges against Giuliani has focused on his possible violation of the Foreign Agents Registration Act, or FARA. At least one of the search warrants reportedly mentioned FARA as the potential crime under investigation. That law requires those engaged in political activities in the United States on behalf of a foreign principal to register with the Justice Department. Giuliani may have violated FARA by failing to disclose his work on behalf of various Ukrainian nationals.

Historically FARA was rarely enforced criminally. But the law has gained prominence in recent years, and during the Trump administration and Mueller investigation there were a number of high-profile FARA cases. Former National Security Advisor Michael Flynn was charged with violating FARA for failing to disclose that he was working for the government of Turkey (although he pleaded guilty to a different charge – before ultimately being pardoned). Former Trump campaign manager Paul Manafort also pleaded guilty to violating FARA for his undisclosed work on behalf of Ukraine.

But a search warrant does not need to name every crime under investigation, and other charges could be implicated as well. Financial crimes such as tax evasion or money laundering are always a possibility. Manafort, for example, also was convicted of tax evasion and money laundering based on his handling of the money he received from Ukrainians. If you’re keeping your work as a foreign agent a secret, you naturally have an incentive to hide payments for that work from the IRS and other authorities.

Another possibility is public corruption – taking part in a conspiracy to bribe president Trump. The first impeachment was essentially about bribery, although the articles of impeachment did not expressly cite that criminal law. The charge was that Trump offered to release military aid to Ukraine in exchange for that country’s help in digging up damaging information about Biden. This is an allegation of quid pro quo bribery: I will do an official act (release the aid) in exchange for something of value to me (the political dirt on my rival).

Giuliani was at the center of all these activities. He appears to have been working with a number of Ukrainians who were seeking something from president Trump — and may have been willing to offer something in return. Prosecutors could be investigating whether such conduct amounted to a conspiracy to commit bribery. A conspiracy charge would not require that the bribe was ever consummated or successful. Nor would it necessarily require charging Trump himself; Giuliani and others could be charged with simply trying to arrange the quid pro quo transaction.

Whether prosecutors are focusing on charges in addition to FARA is just speculation at this point. But it seems unlikely to me that DOJ would have taken the aggressive and politically explosive step of executing the Giuliani search warrants if they were looking only FARA, a relative technicality. That makes me suspect they are looking at something more substantial.

Would Rudy flip?

One tantalizing prospect that all of this raises is whether Giuliani would cooperate in an investigation of Trump in exchange for leniency. It’s hard to imagine Giuliani turning on the man to whom he has so slavishly linked his own image and reputation. But there are reports that their relationship is strained. Michael Cohen, for one, has opined that Giuliani would flip on Trump to save himself “in a heartbeat.”

There also have been reports that Giuliani is seeking Trump’s help in paying his legal fees and that he has not been paid for much of his legal work on Trump’s behalf. That raises some interesting prospects as well. If Giuliani feels like Trump has stiffed him, he may be more willing to cooperate against the former president. On the other hand, given all that Giuliani knows about Trump’s own potential misconduct, if Trump were to help Giuliani with his legal bills that could look like bribery of a witness, in violation of 18 U.S.C. 201: Trump paying Giuliani to keep his mouth shut.

Before this is over, Giuliani may end up wishing he had persuaded Trump to grant him a pardon before leaving office.

William Barr
Former Attorney General William Barr

The Barr Cover-Up

On March 22, 2019, special counsel Robert Mueller delivered his 400+ page report to Attorney General William Barr. Barr did not release the entire report, or the detailed summaries that Mueller prepared for that purpose. Instead, two days later he wrote a four-page letter to Congress purporting to summarize Mueller’s conclusions, and held a press conference. He noted that Mueller had declined to make a prosecutorial decision concerning whether Trump obstructed justice. Barr then announced his own conclusion that the evidence presented by Mueller did not establish that crime.

This extremely misleading letter and press conference set the public narrative for the still-secret Mueller report. It allowed Trump to claim he had been completely exonerated and that Mueller had concluded there was “no obstruction, no collusion.” Mueller himself objected to Barr’s characterization of the report which did, in fact, contain substantial evidence of obstruction of justice by the president. But by the time the full redacted report was released three weeks later, Barr’s “spin” had firmly taken hold.   

Barr testified before Congress that he had reached the conclusions in his letter after consultations with the DOJ Office of Legal Counsel and other Department attorneys. The public interest group CREW promptly filed a request under the Freedom of Information Act for documents related to those consultations. Barr’s DOJ withheld a number of documents, claiming attorney-client and deliberative process privileges. One withheld document in particular, a memo to Barr dated March 24, 2019 from Steven Engel in the Office of Legal Counsel and Ed O’Callaghan in the Deputy Attorney General’s Office, was the subject of a federal court ruling last week.

Federal Judge Amy Berman Jackson ruled on May 3 that the memo must be turned over. Much of her opinion deals with the somewhat dry procedural requirements of FOIA. But her conclusions about DOJ’s behavior are damning.

DOJ had claimed the memo was privileged because it involved DOJ attorneys giving legal advice to Barr concerning whether Trump had obstructed justice. Their story was that these attorneys had reviewed Mueller’s lengthy and detailed report on obstruction, formulated their advice to Barr, and written him a memo, which Barr then used to prepare his letter to Congress – all in the space of a couple of days.

Judge Jackson concluded that these claims were false. The memo itself and Barr’s infamous letter to Congress, she found, were all being drafted at the same time and by the same people. And all of those Trump DOJ officials agreed from the outset that Trump should not be charged with obstruction. The memo was not true legal advice to help Barr decide, but apparently was designed to provide legal cover for a decision that had already been made: “the review of the document reveals that the Attorney General was not then engaged in making a decision about whether the President should be charged with obstruction of justice; the fact that he would not be prosecuted was a given.”

Judge Jackson’s conclusion that the fix was in when it came to obstruction of justice doesn’t really come as a surprise to those who followed the Mueller investigation. Before he was named attorney general, Barr – then a lawyer in private practice – wrote a nineteen page memo to the DOJ about why he believed the president could not be charged with obstruction for anything done in his official capacity. Many considered this memo a sort of job application for the attorney general position. When Trump appointed Barr, he was putting in place a final backstop against any potential obstruction of justice charges. And that’s exactly what he got.

“Disingenuous” = “You’re Lying”

Judge Jackson repeatedly accused Barr’s DOJ of being “disingenuous” before the court in its description of the OLC memo. She held that the affidavits submitted by DOJ officials were “so inconsistent with evidence in the record, they are not worthy of credence.” This is essentially a polite way of accusing the department of lying to the court and engaging in a cover-up about the true reasons for Barr’s actions. 

As Judge Jackson noted in her opinion, she is not the first judge to question Barr’s handling of the Mueller report and the credibility of his statements in court. In an earlier case involving the redactions to the Mueller report, Judge Reggie Walton also expressed his “grave concerns” about Barr’s characterizations of the report, which he found were at odds with Mueller’s actual conclusions. He questioned whether Barr had tried to create a “one-sided narrative” about the report in order to benefit Trump.

Barr and the Trump DOJ desperately sought to prevent the truth about Barr’s shielding of the president from coming to light – so much so that they were willing to lie to more than one federal judge about it. It will be interesting to see now whether the Biden DOJ chooses to appeal Judge Jackson’s order that the memo be turned over. They presumably would like the truth about Barr’s actions to be revealed. But depending on their internal review concerning the merits of Judge Jackson’s conclusions, they may feel they need to appeal to try to protect the institutional privileges potentially at stake. Hopefully the full memo will soon see the light of day.

Barr’s effort to use the Department of Justice to protect the president and his cronies was one of the most disturbing aspects of the Trump years. We saw it with Roger Stone and Michael Flynn. And this episode also ties right back in to the Giuliani story, where the Barr DOJ refused to approve the search warrants that could have unearthed evidence implicating Trump.

It’s apparent that we have still more to learn about the corruption within Barr’s DOJ.

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