to raise the conflicts issue with Rosenstein and leave it to him to decide what to 817 do. McGahn told the President he did not understand the conversation that way and instead had heard, “Call Rod. There are conflicts. Mueller has to 818 go.” The President asked McGahn whether he would “do a correction,” and 819 McGahn said no. McGahn thought the President was testing his mettle to see 820 how committed McGahn was to what happened. Kelly described the meeting 821 as “a little tense.” The President also asked McGahn in the meeting why he had told Special Counsel’s Office investigators that the President had told him to have the Special 822 Counsel removed. McGahn responded that he had to and that his conversations with the President were not protected by attorney-client 823 privilege. The President then asked, “What about these notes? Why do you 824 take notes? Lawyers don’t take notes. I never had a lawyer who took notes.” McGahn responded that he keeps notes because he is a “real lawyer” and 825 explained that notes create a record and are not a bad thing. The President 826 said, “I’ve had a lot of great lawyers, like Roy Cohn. He did not take notes.” After the Oval Office meeting concluded, Kelly recalled McGahn telling him that McGahn and the President “did have that conversation” about removing 827 the Special Counsel. McGahn recalled that Kelly said that he had pointed out to the President after the Oval Office that McGahn had not backed down and 828 would not budge. Following the Oval Office meeting, the President’s personal counsel called McGahn’s counsel and relayed that the President was 829 “fine” with McGahn. Analysis In analyzing the President’s efforts to have McGahn deny that he had been ordered to have the Special Counsel removed, the following evidence is relevant to the elements of obstruction of justice: a. Obstructive act. The President’s repeated efforts to get McGahn to create a record denying that the President had directed him to remove the Special Counsel would qualify as an obstructive act if it had the natural tendency to