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Overnight Delivery March 5, 2019

The Honorable Jerrold Nadler
Chairman, House Committee on the Judiciary
2132 Rayburn Building
Washington, DC 20515

Re: Committee's Document Request of Michael Caputo

Dear Chairman Nadler:

I am in receipt of your letter dated March 4, 2019, in which the Committee requests that my client, Michael
Caputo, produce specific documents by March 18, 2019. In summary, Mr. Caputo is not in possession of any
documentation responsive to your request.

As further follow up to your letter, I received a call from Barry Burke, of the House Judiciary Committee staff,
wherein he inquired as to whether or not Mr. Caputo possessed any responsive documents . Below I elaborate
on my general response to Mr. Burke's inquiry, which he followed-up by asking whether Mr. Caputo will make
himself available to the Committee for an interview. I did not commit to produce Mr. Caputo, principally
because he has already testified under oath twice, in July 2017 before the House Permanent Select Committee
on Intelligence (HPSCI), and again in May 2018 before the Senate Select Committee on Intelligence. In
addition, he was interviewed for more than three hours by the Office of Special Counsel, also in May 2018. On
all three occasions, the inquiries were focused on a so-called Russian collusion investigation. Respectfully, there
are only so many ways the same questions can be asked of Mr. Caputo. We have repeatedly requested the
public release of Mr. Caputo's testimony before HPSCI. Notwithstanding public disclosures that incorrectly
characterize Mr. Caputo's testimony by Members of HPSCI, our request for public release of the transcript has
thus far been denied . We see no reason why the House Judiciary Committee cannot obtain the transcript of
Mr. Caputo's testimony form HPSCI, and we encourage you to do so.

In specific response to your written request, Mr. Caputo is not in possession of any documents relating to the
June 9, 2016 Trump Tower meeting, including documents pertaining to contacts or communications about the
meeting involving President Trump, Donald Trump Jr., Natalia Veselnitskaya, Paul Manafort, Jared Kushner,
Emin Agalarov, Aras Agalarov, Goldstone, or Rinat Akhmetshin. Notably, on June 91 2016, Mr. Caputo was
approximately 500 miles away in Cleveland, Ohio because he had been assigned by the Trump Campaign to
direct communications at the 2016 Republican National Convention.

Similarly, Mr. Caputo is not in possession of any documents relating to any contacts, from January 1, 2015 to
January 20, 2017, between or involving Russian Federation officials, agents, intermediaries, or instrumentalities

Dennis C. Vacco i Partner I dvacco@lippes.com

New York: Albany, Buffalo, New York City • Florida: Ponte Vedra Beach • Ontario: Greater Toronto Area
and President Trump, the Trump Campaign, the Trump Organization, Paul Manafort, Rick Gates, Michael
Cohen, Lieutenant General Michael Flynn, Former Attorney General Jeff Sessions, Jared Kushner, Thomas
Bossert, Roger Stone, Jerome Corsi, George Papadopoulos, Carter Page, Konstantin Kilimnik, K.T. McFarland,
or Erik Prince.

Lastly, Mr. Caputo is not in possession of any documents relating to any contacts from January 1, 2016 to the
present between Paul Manafort or Rick Gates and Konstantin Kilimnik, Serhiy Lyovochkin, or Rinat Akhmetov .
Significantly, Mr. Caputo has never communicated with nor met Serhiy Lyovochkin or Rinat Akhmetov, and is
only familiar with those names through post-election media coverage. Mr. Caputo did meet Kilmnik in the
1990s when Kilimnik worked for the US Government in Moscow during the Clinton Administration. However,
Mr. Caputo has not communicated with Kilimnik since, nor did Kilmnik's name surface at all during Mr. Caputo's
time working on the 2016 Presidential Campaign of Donald J. Trump.

I am available to discuss this matter further with Committee counsel at their convenience .

Very t ruly yours,

Dennis C. Vacco

cc: The Honorable Doug Collins, Ranking Member, House Committee on the Judiciary