SCHEDULE
In accordance with the attached Definitions and Instructions, you, Mark T. Esper, in your
capacity as Secretary of Defense, are hereby required to produce, for the time period from
January 1, 2019, to the present, all documents and communications in your custody, possession
or control referring or relating to:
1. President Trump’s April 21, 2019, and July 25, 2019, telephone conversations with
Ukrainian President Volodymyr Zelensky, including but not limited to:
a. Any recordings, transcripts, notes (including electronic and hand-written notes),
summaries, and draft versions of the official “Memorandum of Telephone
Conversation”;
b. All preparatory memoranda and materials including the full presidential call
package and any addenda; and
c. The identity of all individuals who listened to, participated in, assisted in
preparation for, transcribed, took notes during, reviewed the call record or
transcript, or received information about the April 21, 2019, and July 25, 2019,
telephone conversations;
2. Communications between or among current or former officials of the following entities
relating to the July 25, 2019, telephone conversation:
a. The White House, including the White House Counsel’s Office, the National
Security Council (NSC), the Office of the Vice President (OVP), the Office of
Management and Budget (OMB), or the White House Situation Room;
b. The Department of Justice (DOJ);
c. The Department of State (DOS);
d. The Department of Energy (DOE);
e. Agencies in the Intelligence Community (IC); and
f. The Department of Defense (DOD).
3. Any of the following meetings or potential meetings:
a. Any request, suggestion, or proposal for a telephone call, meeting, visit, or other
communication involving President Trump and President Zelensky;

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 b. A meeting at the White House on May 23, 2019, involving President Trump,
Energy Secretary Rick Perry, former Ambassador Kurt Volker, and/or
Ambassador Gordon Sondland;
c. President Zelensky’s inauguration on May 20, 2019, in Kyiv, Ukraine, including
but not limited to President Trump’s decision not to attend and to send Energy
Secretary Rick Perry to lead the U.S. delegation instead of Vice President Pence;
d. A meeting on or about July 10, 2019, at the White House between Ukrainian
officials Andriy Yermak and Oleksander Danylyuk and U.S. government
officials, including Energy Secretary Rick Perry, former National Security
Advisor John Bolton, former Ambassador Kurt Volker, and Ambassador Gordon
Sondland, including the proposed or actual participation of Vice President Mike
Pence and/or President Trump in the meeting, and any notes or memoranda
related to the meeting that were provided to you or your office;
e. A potential meeting between President Trump and President Zelensky in Warsaw,
Poland on about September 1, 2019, including President Trump’s decision to
cancel his attendance;
f. Meetings and communications between U.S. officials, including but not limited to
Vice President Mike Pence, Energy Secretary Rick Perry, and Senior Advisor
Jared Kushner, and President Zelensky and other Ukrainian government officials
in Warsaw, Poland on or about September 1, 2019;
g. Secretary Pompeo’s September 17, 2019, call with the Ukrainian Foreign Minister
Prystayko;
h. Vice President Pence’s September 18, 2019, call with President Zelensky; and
i. A meeting between President Trump and President Zelensky during the United
Nations General Assembly on or about September 25 2019, including but not
limited to any discussion of their July 25, 2019, phone call, as well as any
preparatory memoranda and materials generated for the meeting; any notes,
readouts, summaries of the same; and any follow-up directives and guidance
formally or informally issued to NSC staff, as well as relevant departments and
agencies, either formally or informally;
4. Efforts by any current or former member of the Trump Administration or Rudolph
(“Rudy”) W. Giuliani, Igor Fruman, Lev Parnas, Semyon (“Sam”) Kislin, Joseph
DiGenova, Victoria Toensing, Vitaly Pruss, or any of their associates, to induce, compel,
petition, press, solicit, request, or suggest that current or former Ukrainian government
officials, politicians, or other persons or entities associated with or acting in any capacity
as a representative, agent, or proxy for any such individuals, investigate matters related to
Burisma Holdings Ltd., Paul Manafort, Hunter Biden, Joseph Biden, the Democratic
National Committee, Hillary Clinton, and/or any U.S. persons or entities;

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 5. The actual or potential withholding, freezing, reviewing, delaying, deferring, directing,
impounding, or releasing of foreign assistance of any kind, including security assistance,
to Ukraine for fiscal year 2019, including communications among or between individuals
in the White House, OMB, OVP, DOD, DOS , DOE, United States Agency for
International Development (USAID), ODNI, or agencies in the IC;
6. The timing, content, and manner for communicating to Congress information regarding
the status of foreign assistance of any kind, including security assistance, to Ukraine,
including but not limited to written Congressional notifications of foreign assistance,
briefings, or any communications referring or relating to information that should or
should not be conveyed and any reasons for the decision;
7. Proposed or actual apportionments or re-apportionments, including footnotes, specifically
withholding obligation of foreign assistance of any kind to Ukraine by DOD, DOS ,
DOE, USAID, ODNI or the IC, including funds appropriated for the Ukraine Security
Assistance Initiative by section 9013 of the Department of Defense Appropriations Act,
2019 (Division A of Public Law 115-245), and for amounts available during fiscal year
2019 within the Foreign Military Financing Program account(s);
8. Deferrals or rescissions of any funding appropriated for foreign aid to Ukraine, including
transmitting a “special message” to the House of Representatives, the Senate, and the
Comptroller General as required by the Impoundment Control Act of 1974;
9. Opinions, advice, counsel, approvals, or concurrences provided by OMB, NSC, the
White House, DOJ, DOD, or DOS on the legality of using apportionments to withhold or
defer the obligation of congressionally appropriated funds to Ukraine;
10. The rate of obligations or expenditure for foreign assistance of any kind provided by
DOD, DOS, DOE, USAID, or IC agencies to Ukraine, including the obligational status
and agency capacity for timely execution under all proposed policy options of all such
assistance;
11. Any delegation or revocation of apportionment authority involving OMB political or
career officials;
12. Planned or actual interagency meetings related to foreign assistance of any kind,
including security assistance, to Ukraine, including but not limited to documents
sufficient to show the identities of all officials who attended interagency meetings on July
18, 2019, July 23, 2019, July 26, 2019, and July 31, 2019, among others;
13. The decision announced on or about September 11, 2019, to provide appropriated foreign
aid to Ukraine for fiscal year 2019, including but not limited to any notes, memoranda,
documentation or correspondence related to the decision; and

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 14. Meetings, calls, or other engagements with Ukrainian officials regarding potential or
actual delays in the provision of funding or implementation of U.S. foreign assistance,
including security assistance, to Ukraine.

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