On January 18, 2019, the President tweeted, “Kevin Corke, @FoxNews ‘Don’t forget, Michael Cohen has already been convicted of perjury and fraud, and as recently as this week, the Wall Street Journal has suggested that he may have stolen tens of thousands of dollars. . . .’ Lying to reduce his jail time! Watch 1066 father-in-law!” On January 23, 2019, Cohen postponed his congressional testimony, citing 1067 threats against his family. The next day, the President tweeted, “So interesting that bad lawyer Michael Cohen, who sadly will not be testifying before Congress, is using the lawyer of Crooked Hillary Clinton to represent him 1068 —Gee, how did that happen?” Also in January 2019, Giuliani gave press interviews that appeared to confirm Cohen’s account that the Trump Organization pursued the Trump Tower Moscow project well past January 2016. Giuliani stated that “it’s our understanding that [discussions about the Trump Moscow project] went on throughout 2016. Weren’t a lot of them, but there were conversations. Can’t be sure of the exact date. But the president can remember having conversations with him about it. . . . The president also remembers—yeah, probably up—could 1069 be up to as far as October, November.” In an interview with the New York Times, Giuliani quoted the President as saying that the discussions regarding the Trump Moscow project were “going on from the day I announced to the day I 1070 won.” On January 21, 2019, Giuliani issued a statement that said: “My recent statements about discussions during the 2016 campaign between Michael Cohen and candidate Donald Trump about a potential Trump Moscow ‘project’ 1071 were hypothetical and not based on conversations I had with the president.” Analysis In analyzing the President’s conduct related to Cohen, the following evidence is relevant to the elements of obstruction of justice. a. Obstructive act. We gathered evidence of the President’s conduct related to Cohen on two issues: (i) whether the President or others aided or participated in Cohen’s false statements to Congress, and (ii) whether the President took actions that would have the natural tendency to prevent Cohen from providing truthful information to the government.