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Interview of: Tyler Robinson

Issuer
Congressional materials
Document type
407055 2024 07 31 Chairman Williams Subpoenas Sba Over Voter Registr Att1
Date
2024-07-31
Case
407055 2024 07 31 Chairman Williams Subpoenas Sba Over Voter Registr Att1

Summary

A transcript of a transcribed interview conducted by the Committee on Small Business of the U.S. House of Representatives on Monday, June 3, 2024, in Washington, D.C. The committee's general counsel, Lauren Holmes, states that Chairman Williams requested the interview as part of the committee's oversight of the Small Business Administration's voter registration efforts. The interviewee, a special advisor to the SBA Administrator, appears voluntarily with counsel from Cooley LLP, and SBA General Counsel Therese Meers appears for the agency. The agreed scope covers a video, senior officials' travel, SBA voter registration activities and political activity. His opening statement says he did not see official time or resources used for campaigning and had no role in the SBA's Memorandum of Understanding with the State of Michigan. The interview adjourned at 2:06 p.m.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

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COMMITTEE ON SMALL BUSINESS,

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U.S. HOUSE OF REPRESENTATIVES,

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WASHINGTON, D.C.

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INTERVIEW OF:

TYLER ROBINSON

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Monday, June 3, 2024

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Washington, D.C.

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The interview in the above matter was held in room 6400, O'Neill House Office
Building, commencing at 10:02 a.m.


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Appearances:

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For the COMMITTEE ON SMALL BUSINESS:

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ALEX ALBRECHT, COUNSEL

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ANDREW COFFIELD, PROFESSIONAL STAFF MEMBER

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CHRIS ECKHARDT, LAW CLERK

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LAUREN HOLMES, GENERAL COUNSEL

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RENATA BECA-BARRAGAN, MINORITY SENIOR COUNSEL

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ELLEN HARRINGTON, MINORITY DEPUTY STAFF DIRECTOR

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For the SMALL BUSINESS ADMINISTRATION:

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THERESE MEERS, GENERAL COUNSEL

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JUAN SEMPERTEGUI, DEPUTY GENERAL COUNSEL

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JAIME CANTLON, ASSOCIATE GENERAL COUNSEL

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GEORGE HOLMAN, ASSOCIATE ADMINISTRATOR FOR CONGRESSIONAL AND LEGISLATIVE

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AFFAIRS


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For TYLER ROBINSON:

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SUSANNE SACHSMAN GROOMS

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HEATHER SAWYER

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ROBERT DENNISTON

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Cooley LLP


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Ms. Holmes.

This is a transcribed interview of Mr. Tyler Robinson, conducted by

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the Committee on Small Business under the authority granted under House rule X and the

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rules of the Committee on Small Business.

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Chairman Williams as part of the committee's oversight of the Small Business

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Administration's voter registration efforts.

This interview was requested by

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Can the witness please state his name and spell their last name for the record?

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Mr. Robinson.

Tyler Robinson, R-o-b-i-n-s-o-n.

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Ms. Holmes.

Thank you.

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Mr. Robinson, my name is Lauren Holmes, and I'm the general counsel for the

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Committee on Small Business, and I want to thank you for coming in here today.

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committee recognizes you're here voluntarily, and we appreciate that.

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Under the committee's rules, you are allowed to have an attorney present to

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advise you during this interview.

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personal capacity present with you today?

Do you have an attorney representing you in a

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Mr. Robinson.

Yes.

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Ms. Holmes.

Can the attorneys please -- I guess we'll just go down the

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The

line -- state your name for the record?
Ms. Grooms.

Sure.

My name is Susanne Sachsman Grooms.

I'm from Cooley.

I have with me two attorneys from Cooley.

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Ms. Sawyer.

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Mr. Denniston.

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Ms. Holmes.

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Is there also an attorney present representing the agency today?

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Ms. Meers.

Yes, there is.

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Ms. Holmes.

Will the counsels please identify themselves for the record?

Heather Sawyer from Cooley, representing Mr. Robinson.
Robert Denniston from Cooley, representing Mr. Robinson.

Thank you.


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Ms. Meers.

Yes, we will.

Therese Meers, general counsel for the SBA, agency

counsel.

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Mr. Sempertegui.

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Mr. Cantlon.

Jaime Cantlon, associate general counsel, representing SBA.

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Ms. Holmes.

And then also the final SBA member?

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Mr. Holman.

George Holman, associate administrator for congressional and

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Juan Sempertegui, deputy general counsel, representing SBA.

legislative affairs.

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Ms. Holmes.

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For the record, starting with majority staff, can the additional staff members

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Thank you.

please introduce themselves with their name, title, and affiliation?
Mr. Eckhardt.

Christopher Eckhardt, law clerk to the majority staff with the

House Small Business Committee.

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Mr. Albrecht.

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Business Committee.

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Mr. Coffield.

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Business Committee, majority.

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Ms. Harrington.

Alex Albrecht, counsel for the majority staff for the House Small

Andrew Coffield, professional staff member for the House Small

Ellen Harrington, deputy staff director, House Small Business

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Committee, minority staff.

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Ms. Beca-Barragan.

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Renata Beca-Barragan, senior counsel, House Small Business

Committee staff.

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Ms. Holmes.

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Mr. Robinson, before we begin, I'm going to go over some of the ground rules for

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Thank you.

this interview.

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As previously agreed to by counsel for Mr. Robinson and the majority staff, the

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scope of this interview is Mr. Robinson's knowledge of a video, the Administrator and


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other senior officials' travel, SBA's activities related to voter registration, and the SBA or

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the Administrator's participation in political campaigns or political activity.

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The way this interview will proceed is as follows:

The majority and minority staff

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will alternate asking you questions, 1 hour per side per round, until each side is finished

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with our questioning.

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minority staff will have an hour to ask questions.

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in this manner until both sides have no more questions.

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The majority staff will begin and proceed for an hour, and then
We will then alternate back and forth

If either side is in the middle of a specific line of questions, they may choose to

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end a few minutes past an hour to ensure completion of that specific line of questioning,

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including any pertinent followups.

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In this interview, while one member of the staff for each side may lead the
questioning, additional staff may ask questions.
There is a court reporter taking down everything I say and everything you say to

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make a written record of this interview.

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staffer questioning you has finished each question before you begin your answer, and the

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staffer will wait until you finish your response before proceeding to the next question.

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Further, to ensure the court reporter can properly record this interview, please

For the record to be clear, please wait until the

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speak clearly, concisely, and slowly.

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answers, such as nodding or shaking your head, so it is important that you answer each

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question with an audible, verbal answer.

Also, the court reporter cannot record nonverbal

Do you understand?

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Mr. Robinson.

Yes.

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Ms. Holmes.

We want you to answer our questions in the most complete and

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truthful manner possible, so we will take our time.

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fully understand the question, please let us know and we will attempt to clarify, add

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context to, or rephrase our questions.

If you have any questions or do not

Do you understand?


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Mr. Robinson.

Yes.

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Ms. Holmes.

If we ask about specific conversations or events in the past and you

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are unable to recall the exact words or details, you should testify to the substance of

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those conversations or events to the best of your recollection.

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a conversation or event, you should give us your best recollection of those events and

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parts of the conversation that you do recall.

If you only recall part of

Do you understand?

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Mr. Robinson.

Yes.

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Ms. Holmes.

Although you're here voluntarily and we will not swear you in, you

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are required, pursuant to 18 U.S.C., Section 1001, to answer questions from Congress

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truthfully.

This also applies to questions posed by congressional staff during an

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interview.

Do you understand?

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Mr. Robinson.

Yes.

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Ms. Holmes.

If at any time you knowingly make false statements, you could be

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subject to criminal prosecution.

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Mr. Robinson.

Yes.

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Ms. Holmes.

Is there any reason you're unable to provide truthful testimony in

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today's interview?

Do you understand?

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Mr. Robinson.

No.

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Ms. Holmes.

Please note that if you wish to assert a privilege over any

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statement today, that assertion must apply within the rules of the House and the

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Committee on Small Business.

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For the chair to consider assertions of privilege over testimony or statements,

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witnesses or entities must clearly state the specific privilege being asserted and the

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reason for the assertion on or before the scheduled date of testimony or appearance.

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Do you understand?


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Mr. Robinson.

Yes.

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Ms. Holmes.

Ordinarily, we'll take a 5-minute break at the end of each hour of

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questioning, but if you need a longer break or a break before that, please let us know and

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we're happy to accommodate.

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we would ask that you finish answering the question before we take a break.

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understand?

However, to the extent that there is a pending question,

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Mr. Robinson.

Yes.

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Ms. Holmes.

Do you have any other questions before we begin?

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Mr. Robinson.

No.

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Ms. Harrington.

Lauren, may I ask a question, please?

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Ms. Holmes.

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Ms. Harrington.

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Ms. Holmes.

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Absolutely.

O'Keefe -Ms. Harrington.

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Ms. Holmes.

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Ms. Harrington.

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Ms. Holmes.

That one is the one that was secretly recorded?

Diced and spliced?

If you have objections to the video, you can make it when we get to

that point.
Ms. Harrington.

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Ms. Holmes.

We do have objections to the video --

Okay.

You can make them at beginning of your hour.

Thank

you.

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Ms. Harrington.

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Ms. Holmes.

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Okay.

Correct.

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What video were you referring to on the scope?

The video that Mr. Robinson was in that was on Twitter, the James

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Do you

Thank you.

I understand you have a statement for the record, Mr. Robinson.

You may go ahead and proceed.


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Mr. Robinson.

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Thank you for the opportunity to say a few words before we begin this morning.

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My name is Tyler Robinson.

Thank you.

I am from North Carolina, and graduated from

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North Carolina State in 2015 with a degree in political science.

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2022, to work for the Small Business Administration as special assistant to the

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Administrator, and was promoted to the position of special advisoer to the Administrator

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late last year.

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I came to Washington in

I'd like to make three brief points before we begin this morning.

First, I would

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like to explain my work at the SBA.

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provided administrative support to Administrator Guzman.

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by compiling her daily briefing book which listed each day's events and included brief

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background memos for her meetings.

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these event memos, highlighting logistical details about the event, they were usually

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written by the SBA program office responsible for the subject matter of each meeting.

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As special advisoer with the rank of GS-12, I
I assisted with her schedule

While I occasionally helped draft portions of

I was also part of a team that provided background and made recommendations

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about her schedule, but I was not responsible for the final decisions regarding her

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schedule or travel.

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meeting, and I am not involved in setting or executing SBA policy.

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I was not responsible for deciding who to invite to any given

My interactions with the White House regarding the Administrator's travel mostly

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involved compiling a list of the Administrator's completed and upcoming travel each

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week, which I emailed to the SBA's White House liaison who then emailed the report to

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the White House Office of Cabinet Affairs.

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Cabinet Affairs would occasionally reach out directly to me with a logistical question

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about the information in the report.

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Individuals at the White House Office of

I have never discussed the Administrator's or SBA's travel with Jeff Zients, the


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White House chief of staff, and I am personally not aware of the White House directing

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the travel of the SBA, including the Administrator.

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the Administrator is responsible for determining her own meeting and travel schedule.

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It is her job to meet with small businesses, explain what we do, and how our work and

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policies benefit their businesses and communities.

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its policies, and her goal is to travel to all 50 States, visiting with small business owners of

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all backgrounds.

In fact, it is my understanding that

She travels to promote the SBA and

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In my work at the SBA, I have not seen the Administrator or anyone else at the

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SBA use official time or resources to campaign for President Joe Biden or anyone else.

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am also not involved in scheduling or supporting any nonofficial travel or activities of the

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Administrator.

I

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Second, I want to clarify that I have no role in the SBA's Memorandum of

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Understanding with the State of Michigan, which I understand is of interest to the

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committee.

I am not familiar with the MOU.

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it involves.

My only memory of any discussion about it was a mention during a meeting

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about the press release announcing the MOU.

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about the MOU to share with you.

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In sum, I don't have any information

Third, I want to address the video that was posted online by the O'Keefe

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Media Group.

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with me.

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I do not know how it came about or what

I believe this video is the reason that the committee has asked to speak

In March 2024, I was contacted on a dating app by a person who identified herself

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as Grace.

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personal dates.

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ardent Democrat who was concerned that President Biden would not win reelection and

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questioned me repeatedly about what the SBA was doing to help him.

We ended up meeting twice over drinks and dinner on what I believed to be
Grace, which may not be her real name, represented herself as an


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I know now that she was lying to me and that she was recording me without my

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knowledge or consent.

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internet.

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watching the video that someone has clipped and selectively reordered statements to fit

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their false narrative about the SBA.

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I first learned of the secret recording when it was posted to the

I have never seen the unedited footage of our two dates, but it is clear from

Watching the video is embarrassing.

It is painful to see myself trying to impress

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a date, only to learn, along with the rest of the world, that she was lying and tricking me

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all along.

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overstated my role with the SBA, as well as my knowledge of the workings of the

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White House.

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White House and who is involved.

It is also uncomfortable to admit that in trying to impress my date, I

I have no personal knowledge of how decisions are made in the

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And in trying to make my date feel less anxious about the November election, I

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found myself agreeing with misstatements that she made and making misstatements

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myself.

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The result is a selectively edited, misleading video.
In the video, I agree to and say things that are not accurate and do not reflect the

agency's true nature, true work, or priorities.
I am personally responsible -- or sorry -- personally sorry for any confusion or
misunderstanding that this has caused about the SBA or Administrator Guzman.
I have also been personally hurt by the social media backlash.

With my name

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being public, people have found my public profiles and attacked me, requiring me to

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suspend social media accounts to ensure my safety.

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I hope that my testimony today helps correct any false impressions that the
committee may have gotten from this doctored and dishonest video.

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Thank you, and I look forward to your questions.

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Ms. Holmes.

Thank you, Mr. Robinson.


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The time is now 10:15, and the majority will begin their first hour of questions.

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EXAMINATION

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BY MS. HOLMES:

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Q

How long have you worked at the SBA in any capacity?

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A

I started on May 31st, 2022, is my best recollection as the start date.

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Q

Where did you work prior to the SBA?

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A

I worked for the Biden for President campaign.

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Q

Do you remember what timeframe that was?

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A

I believe I started in August 2020 and ended in December 2020.

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Q

Okay.

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A

I worked for the Kamala Harris for President campaign.

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Q

Okay.

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A

As best of my recollection, it was starting in May 2019 and ending in

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December 2019.

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Q

Okay.

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A

Yes.

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Q

Do you recall?

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A

Yes.

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Q

Okay.

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A

And during the 2016 election, I worked for Governor Roy -- or Attorney

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And where did you work before that?

Do you remember the dates of that one?

Did you have any political jobs before that?

During the fall of 2018, I worked for the Iowa Democratic Party.

General Roy Cooper's first gubernatorial campaign.

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Q

Okay.

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A

And in 2014, I worked for the North Carolina Democratic Party.

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Q

Okay.

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A

2012, I was in college.

Where did you work in 2012?
I volunteered briefly for the Obama campaign.


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Q

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your role there?

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A

My role was, in North Carolina, as regional political director.

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Q

Okay.

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A

I was in charge of the western half of the State, coordinating outreach to

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You said you were in the Biden for President campaign.

What did that look like?

What was

Like, what were your responsibilities?

elected officials and candidates from the State.

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Okay.

Q

Okay.

Did any of that work sort of build up to where you got your eventual

role at SBA -- coordinating, scheduling, those sorts of things?

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A

I can't say for sure why the SBA hired me, but I believe so.

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Q

What made you want to go to the SBA?

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A

The SBA has -- does amazing work and has a great mission of helping small

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business owners from across America, and as someone who has worked in small

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businesses, I understand the struggles they face and how important they are to the

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community.

So I thought it would be very rewarding work.

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Q

You said you had experience in small businesses?

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A

Correct.

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Q

Was that from restaurants -- or what sort of small businesses did you work

A

In high school and then later sometimes in between in college, I would work

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in?

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for a car dealership, delivering parts as a parts driver.

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myself returning to college, I did work at restaurants.

And then in college and prior to

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Q

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Have any of the supervisors you've had on any of the campaigns we just walked

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That's always a hard job.

through come over with you at the SBA?
A

No.

Do you work with any of them now?


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Q

Okay.

For the first role at SBA -- you said that started in May of

2022 -- what was that role?

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A

I believe it was in May 2022 --

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Q

Okay.

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A

-- was the official start date.

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Q

Okay.

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A

No.

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Q

Oh.

Okay.

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A

Yes.

For the first around year and a half, my title was special assistant to

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the Administrator.

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Administrator.

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Q

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responsibilities?

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A

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daily briefing book.

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scheduling until we hired someone for that position.

It was special assistant to the Administrator.

So the same title you had at the time of the video?

Can you walk me through your titles at SBA?

Late last fall, I was promoted to special advisoer to the

For your special assistant role first, what were your day-to-day

My main responsibility, as I mentioned in the statement, was compiling her
And then I also served for a time as an interim director of

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Q

Okay.

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A

And then the rest of the role is providing administrative and operational

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support for the Administrator and the front office.
Q

And so that was things that you talked about in your statement -- scheduling,

briefing books, things of that nature?

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A

Yes.

Logistical arrangements for the Administrator.

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Q

Okay.

And then you were promoted in the fall of 2022 -- or '23?

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A

Correct.

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Q

'23?

Okay.

And how did your role change with that promotion?


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A

I continued to do the roles assigned as the special assistant, minus some of

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the minor logistical details and operational things.

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of the Office of Public Engagement.

And then I assisted more in the work

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Q

And what did that work look like?

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A

That work generally involved helping organize and plan and execute events

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for the Administrator with external partners.

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Q

What kind of external partners?

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A

Trade organizations, interest groups, small businesses.

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Q

Does that include like resource partners like SBDCs?

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A

Correct, yes.

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Q

Okay.

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A

There are businesses, but I do not know if they're labeled nonprofit or not.

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Q

That's okay.

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A

My current role is providing communications and public affairs strategy to

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Any nonprofits?

So what is your current role at the SBA?

the Office of Disaster Recovery and Resiliency.

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Q

Okay.

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A

That change started the beginning of May 2024.

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Q

And why did you make that switch?

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A

Earlier in 2024, around January or February, I had requested to be able to

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When did that change happen?

take part in more of the SBA's program activities and offices.

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Q

Okay.

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A

And I had expressed interest in two offices, one being ODR&R.

And around

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April, as I understand it, the associate administrator requested assistance and more staff,

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and I was internally detailed.

25

Q

The associate administrator for OSC?


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1

A

For ODR&R.

2

Q

Oh, for ODRR.

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And so then you made that transition in May?

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A

Correct.

5

Q

Okay.

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A

I do not.

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Q

In the video you mentioned that you worked for the chief of staff.

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Okay.

Do you still meet with the Administrator, provide any assistance to

her?

Who

were you talking about?

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A

I was referring to the chief of staff of the SBA, Arthur Plews.

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Q

Okay.

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A

At the time of the video, yes.

14

Q

When did you work for him?

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A

As far as I remember, he was my direct superior when I started at the SBA.

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Q

Okay.

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A

And then when they hired the director of scheduling and advance, I was

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So did you work directly for him at the time?
At other times throughout my tenure, I did

not.

moved to their jurisdiction.

19

Q

Okay.

20

A

And then she left that role, and I went back to Arthur.

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And then I am now

under Francisco Sanchez.
Q

Okay.

You said you worked on scheduling events for the Administrator in

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both of your roles, I guess, to some extent.

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the Administrator in scheduling, did you receive requests and bring those up to the

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Administrator, or how did her scheduling process go?

When you were the -- in your first role for


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1

A

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account.

3

Q

Okay.

4

A

It is a separate inbox.

5

Q

A separate inbox.

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Did requests ever come directly to your inbox?

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A

Occasionally.

8

Q

Okay.

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send it to?

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Yes, we received requests from outside organizations through an email

Ms. Grooms.

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Was it your email account or was there a separate box for events?

Okay.

And that's just because people got confused or didn't know who to

If you know.

BY MS. HOLMES:

12

Q

If you know.

13

A

Yeah, I'm not sure.

14

Q

Okay.

15

A

The Administrator receives various invites from trade organizations,

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What kind of events were people reaching out to schedule?

nonprofit groups, individuals, small business owners, for her to speak or attend events.

17

Q

How do you decide which ones get escalated up to her?

18

A

We meet as a team, and the first priority -- or first criteria is, for the date

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of -- is the Administrator available for the date required, and if not, is there any room

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to -- wiggle room.

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level.

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that time and if the event matches those priorities or what we are trying to promote.

The second criteria is, is this event going to be at the Administrator's

And then finally, we consider the priorities of the SBA and the Administrator at

23

Q

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criteria for that?

25

A

Okay.

For deciding if it's at the Administrator level or not, what are the

There's no official criteria.

That's just something that is a feel.


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1

Q

Okay.

2

A

Correct.

3

Q

Okay.

4

A

The chief of staff --

5

Q

Okay.

6

A

-- the deputy chief of staff, myself, the director of advance, the director of

And, like, the team decides kind of as a group?

Who was on that team, to the best of your recollection?

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scheduling, the associate administrator of the Office of Congressional and Legislative

8

Affairs, the associate administrator of the Office of Field Operations, the associate

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administrator of the Office of Communications and Public Liaison, the counselor to the

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Administrator, and various members of the public engagement team.

11

Q

Was that done in person, on Zoom, both?

12

A

Both.

13

Q

Both.

14

The Office of Field Operations' associate administrator, who was that

at the time?

15

A

It is Jennifer Kim.

16

Q

Still Jennifer Kim.

17

A

Correct.

18

Q

Okay.

And she was at the time when you worked in this role?

For the policies and procedures for establishing those three criteria

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you outlined, is that something that's written down or is that something someone just

20

verbally says, hey, this is how we decide on events?

21

A

That is how I would characterize it.

22

Q

Okay.

23

A

It is not written down --

24

Q

Okay.

25

A

-- and never been explained to me.


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1

Q

Okay.

2

A

Just through years of work in public engagement and event management

Q

Okay.

3
4
5

So how did you learn how to categorize events?

roles.
In the third criteria you outlined, you mentioned the priorities of the

SBA and the Administrator.

How did you determine what priorities were?

6

A

They mainly involve around what the SBA is working on at the moment.

7

Q

Okay.

8

A

They also involve around special months to highlight the achievement of

9

certain demographics.

10

Q

When you say certain demographics, who are you talking about?

11

A

For instance, Black History Month, we like to highlight the work of

12

African-American business owners.

13

months.

14

Q

Okay.

15

A

It varies week to week.

16

Q

Would you say she travels on a weekly basis, once a month, twice a month,

17

five events a week?

18

A

I would say, in general, she takes one trip a week.

19

Q

Okay.

20

A

I have.

21

Q

Did you go on most of them, some of them, not many?

22

A

I went on a minority of trips as the advance staff.

23

Q

Okay.

24

A

The advance staff arrives the day before the events, along with the security

25

Same thing for the other heritage and history

How often did the Administrator travel?

Did you ever go with her on those trips?

And what does advance staff do?

detail, and they walk through the events that will be happening the next day, just to make


20

1

sure the logistics, the people we are visiting with understand what will happen and things

2

of that nature, just prepping for the day.

3
4

And then the day of the event, you walk and guide the Administrator through the
events, jumping from place to place, once again, just making sure everything's okay.

5

Q

6

Administrator?

7

associate administrators?

Okay.

Are there events that you helped plan that didn't include the

Would you ever do advance for like the deputy administrator or other

8

A

I did not.

9

Q

Okay.

10

the time?

11

A

For individual meetings, we had no set schedule.

12

Q

No set schedule.

13

On average, how often would you say you met with her?

14

A

For a meeting, once a week.

15

Q

Once a week.

16

Okay.

17

How often do you meet with the Administrator, daily -- or did you, at

Okay.

And then you said you did her daily briefing books, and those included

events, upcoming, and other meetings she had throughout the day, right?

18

A

Correct.

19

Q

When you wrote those, did you have any discretion over what was on her

20

calendar or was that dictated down to you?

21
22

A

25

I was just putting into the book what

the -- what her calendar for the day was.

23
24

I did not decide the calendar.

Q

Okay.

A

Correct.

email?

And then you just dropped it off in her office or sent it to her via


21

1

Q

Which one?

2

A

Both.

3

Q

Both.

4

When you worked under Mr. Plews, how often did you meet with him, on

Sorry.

Okay.

5

average?

6

A

Once every 2 weeks we had our one-on-one.

7

Q

One-on-one.

8

Did you bring him the Administrator's schedule or was that just a separate role?

9

A

I had no responsibilities bringing Arthur a schedule or anything else.

10

Q

Okay.

11

A

He was just my direct superior, so he was the person I reported to for time

12
13
14

Okay.

What did you do for Mr. Plews?

off, things of that nature.
Q

Okay.

Did he have authority to dictate what your day looked like or what

meetings you would take?

15

A

Yes.

16

Q

Okay.

17

A

No.

18

Q

Okay.

In your role, did you oversee any other staff?

During your time with the SBA, in any of your roles, did you ever

19

interact or work with a person named Jessica Reeves who's the director of public

20

engagement?

21

A

Yes.

22

Q

Okay.

23

A

Mainly, my interactions would be asking for briefing material for the events

24
25

What was your interaction like with her?

that the Office of Public Engagement were running.
Q

Was that via email?

On the phone?


22

1

A

All the -- via email, Teams, and in person.

2

Q

Okay.

Did Ms. Reeves have any discretion over what went on the

3

Administrator's calendar?

4

Ms. Grooms.

If you know.

5

Mr. Robinson.

No, not that I'm aware.

6

Ms. Holmes.

Okay.

7

Ms. Meers.

Can we take a pause?

8

I'm not sure he can speak to his duties at

other -- at the agency.

9

Ms. Holmes.

It's just to the best of his knowledge.

10

Ms. Meers.

Yeah, because he's not --

11

Ms. Holmes.

He's not them, yeah.

12

Ms. Meers.

-- he's not them.

13

Ms. Holmes.

He controlled the schedule, so I think he would have an idea of

14

He's not her supervisor.

He's not --

who sent him things to put on the schedule.

15

Ms. Grooms.

Just for the record, he did not control the schedule, though.

16

Ms. Holmes.

Yeah, you're right.

17

can strike down.

18
19

That was an unfair characterization that we

BY MS. HOLMES:
Q

All right.

To the best of your recollection, when you received calendar

20

invites, you went into these meetings with the full team, and then the full team said, this

21

is what goes on her calendar, this is what does not.

22

A

How often did that full team meet?

I would not say this is what goes on her calendar.

We simply made a

23

recommendation to the Administrator, and she decided which events we approved or

24

declined for.

25

Q

Okay.


23

1

A

That team met once a week.

2

Q

Once a week.

3

Were there any events that came up in between the weeks that were maybe next

4

day or more immediate that the Administrator would have to make a determination on in

5

real time?

6

A

I do not recall.

7

Q

Okay.

8
9

If you got an email about an event that was maybe perhaps right

after your weekly meeting, what would you do with that, if it was in the next few days?
A

As far as I can recall, most of the time, we would have to decline because we

10

could not prepare the Administrator or vet the event in enough time.

11

when we would reach back out and ask if this can be moved to a later date.

12

Q

Okay.

13

A

And by "we," I mean the director of scheduling.

14

contact.

15

Q

Okay.

There are times

I would not make that

For these events like you just mentioned, they probably take a

16

decent amount of time to plan.

17

process for the events?

18

time the event got put on the calendar to the time that the event was executed and

19

finalized, what was your role?

20

A

What was your involvement like with the planning

I know you said you did day before sometimes, but from the

For the vast majority of events I had no role in actually planning the event or

21

the content of the event.

22

briefing material for the event and collecting that material.

23
24
25

Q

And when you say who's responsible for the briefing material, do you mean

offices or individuals?
A

My main role was just assigning who was responsible for the

Both.


24

1

Q

Okay.

2

A

Sometimes it is assigned to an office, sometimes to a certain individual.

3

Q

Okay.

4

assignments?

5

A

The nature of what the event was focusing on.

6

Q

Can you give me an example?

7

A

This is just not a factual event that happened --

8

Q

Okay.

9

A

-- but just an example.

How did you make those determinations of who was getting what

If the event focused on government contracting,

10

someone from the Office of Government Contracting and Business Development would

11

be assigned the memo.

12
13
14
15
16
17

Q

And then they transmit it back to you for you to put in the briefing book,

or where does it go from there?
A

Once the memo is written and approved by that office, it was sent to me to

put into the briefing book.
Q

Okay.

Were events different if they were SBA-sponsored events versus an

event that you did with like an SBDC locally, or was it all -- the prep work all the same?

18

A

Define -- yeah, define "different."

19

Q

So in preparing for, like, just an SBA-sponsored event versus preparing for a

20

SBA-sponsored event with a resource partner or a third party.

21

A

22

different.

23

Q

24
25

No.

Okay.

businesses?
A

No.

The event -- or the general procedure, as I understand it, was not

Did you have any role in advertising these events to small


25

1

Q

2

these events?

3

A

I do not.

4

Q

So I want to ask a few questions about mixed travel.

5

Okay.

Do you happen to know how small businesses can find out about

Are you aware of

what mixed travel is under the Hatch Act?

6

A

Yes.

7

Q

Okay.

8

A

I am aware that the Administrator, as I understand it, is allowed to do

How are you aware of that?

9

political activity, but the SBA is not allowed to pay for or use any SBA resources during

10

that activity.

11

Q

So did you ever help with events that would eventually become mixed travel,

12

like, did you do the first event -- I know sometimes they do an official event and then a

13

political event.

14

involved in events that also had a political aspect to it?

I think that's how the OSC defines "mixed travel."

15

A

I was not, as far as I'm aware.

16

Q

Okay.

17

Ms. Grooms.

18

[Discussion off the record.]

19

Mr. Robinson.

20

activities.

21

Did you -Can we just take a moment?

And to add, I don't know the Administrator's political travel or

I was never involved in any of those.
BY MS. HOLMES:

22

Q

Those are kept separate, right?

23

A

Yes.

24

Q

Okay.

25

So were you ever

Are you trained under the Hatch Act when you become part of the

SBA, on what's allowed and what's not?


26

1

A

Yes, we receive guidance from our Office of General Counsel.

2

Q

How is that guidance transmitted to you?

3

A

We are regularly given briefings on what is allowed and what is not allowed.

4

Q

By regularly, do you mean annually, biannually?

5

A

To the best of my recollection, it is twice a year.

6

Q

Are you required to go to those?

7

A

Yes.

8

Q

Did you attend them?

9

A

Yes.

10

Q

Do you remember when your last one was?

11

A

The last one, as far as I can remember, was I believe earlier this year.

12
13
14

It

might've been late last year.
Q

Okay.

You said you didn't remember or, to the best of your recollection,

did not work on any events that had any mixed travel.

Is that right?

15

A

Correct.

16

Q

Were you given any training on if those events would've occurred, how you

17

To the best of my recollection, I had no involvement.

were supposed to handle things?

18

A

As far as I remember, I was not.

19

Q

Okay.

Okay.

All right.

I think we're going to turn to the video now

20

which, as we discussed beforehand, was the kind of onus of bringing you in here today.

21

I know you mentioned in your statement that it was a secret recording that you were

22

unaware of at the time and that it was spliced.

23

So I think for the purposes of setting the base here, could you characterize what

24

you believe to be incorrect about the video?

25

Could you just correct for the record what you said was a misstatement of fact in the

You said you made statements of misfact.


27

1

video that is something you are holding today as not true?

2

A

Yes.

3

Q

Okay.

4

A

-- I made in the video.

5

[Discussion off the record.]

6

Mr. Robinson.

7

[Discussion off the record.]

8

Mr. Robinson.

There are quite a few statements --

Is -- I can't -- yeah.

So as far as I can remember, in the video -- let's see.

Let me see here.

In the video, you know, I overstated my role

9

with the SBA and my knowledge of the workings with the White House.

10

referred to how decisions are made in the White House, and I have no direct knowledge

11

of how those decisions were made.

12

SBA and the Administrator to travel to certain States.

13

heard or seen, as far as I can remember, the White House direct travel to any States, nor

14

have I heard or seen, to the best of my recollection, the White House direct who to invite

15

to any given event.

16

In the video I also state the White House directs the
That is not true.

I have never

And --

BY MS. HOLMES:

17
18

In the video I

Q

So to clarify that one real quick, you never saw an email come in from the

White House requesting the Administrator at an event?

19

A

I have received email invitations from the White House, but never have I

20

received or seen, as far as I can remember, a directive that the Administrator attend an

21

event.

22

Q

Okay.

So when an email came from the White House, was that something

23

you just considered the same level as coming from a trade group or was that something

24

that was considered as a higher priority?

25

A

I believe it was something that we considered at the same level and if we


28

1

were available.

2

Q

3

dispute.

Yeah.

Okay.

Sorry.

You can -- if there's other things you wanted to

4

I know we have that all on the record at the beginning too, but I didn't know if

5

there was any specific statements you wanted to refute on top of what you put in your

6

initial statement.

7

A

I would say, in the video I mentioned travel to Montana.

8

Q

Okay.

9

A

The White House never directed any travel to Montana.

10

They never, as far as I can remember, as far as I've seen, directed who to invite to

11
12

any event or who not to invite.
Q

Okay.

For Montana, did you ever get an email invitation from the

13

White House for Montana?

14

invitation to go to Montana?

I know you said they didn't direct it, but was there ever an

15

A

No, not as far as I can recall.

16

Q

Okay.

17

A

Without seeing a transcript, I can't recall what is --

18

Q

Yeah.

19

A

-- said in the video.

20

Q

No, that's okay.

Were there any other statements you wanted to refute at the top?

We're going to walk through a couple of the quotations

21

from the video as well, but I wanted to just give you the opportunity at the beginning to

22

dispute.

23
24
25

So the video that we've been discussing on the record is the April 17th video
released by James O'Keefe, containing footage of you and some allegations.
You said you became aware of this video on Twitter.

Is that right?


29

1
2

A

The evening the video was posted, I received a call from our chief of staff

notifying me that the video was made public.

3

Q

Okay.

4

A

In general, I would say shock and embarrassment.

5

Q

Did anyone else at the SBA reach out to you to talk about it?

6

A

Yes.

7

Q

Can you let us know who?

8

A

Mike Rodriguez -- Michael Rodriguez, the head of the Administrator's

9

security detail --

10

Q

Okay.

11

A

-- called to talk about the video and get background, as a security measure.

What was your reaction to that?

12

And the associate administrator for the Office of Congressional and Public Liaisons, we

13

talked about the video -- or the video being the subject of an invitation I received for a

14

transcribed interview from this committee.

15
16

Q

Okay.

And I think you mentioned in your statement that, for security

purposes, you took down your social media and things of that nature.

Was that -- sorry.

17

A

You can finish the question.

18

Q

Was that something that Mr. Rodriguez directed you to do or was that just

19

I'm sorry.

something you thought would be for your own personal safety?

20

A

I was never directed to do that.

21

Q

Okay.

It was for my own personal well-being.

As I'm sure you are aware, the committee condemns any acts

22

against you as a result of this video or as a result of this transcribed interview.

23

not condone any action taken against you because of this, so just wanted to get that on

24

the record.

25

Are you the individual in the video?

We do


30

1

A

Yes.

2

Q

Okay.

So throughout the video, you name a number of individuals.

Now,

3

Ron Klain was one you mentioned in your opening statement as someone you hadn't

4

really worked with.

5

A

I have never had any interactions with Ron Klain.

6

Q

Okay.

7

A

I have never had any interactions with Mr. Ricchetti.

8

Q

Anita Dunn?

9

A

I have met Anita Dunn once and shook her hand, and that's the extent of my

10

Can you describe the nature of your interactions with Ron Klain?

What about Steve Ricchetti?

interactions with Anita.

11

Q

Was that just like at an SBA event or something?

12

A

Yes.

13

Q

Okay.

14

A

I have never met Mr. Sperling or had any interactions with him.

15

Q

And Jeff Zients?

16

A

The same.

17

Q

You said you worked with the SBA White House liaison, right?

18

A

Yes.

19

Q

Okay.

20

A

My interaction with the White House liaison was compiling a list of the

Gene Sperling?

I have never met or had any interactions with Mr. Zients.

What were your interactions with them about?

21

Administrator's previous travel for the week and then her upcoming travel, and I would

22

email that to the White House liaison.

23

Q

For the record, who is that?

24

A

Destine Hicks Lundy.

25

Q

Is she employed by the SBA or the White House?


31

1

A

She is employed by the SBA, as far as I know.

2

Q

Okay.

3

member of the Cabinet, quote, like pretty much every week.

4
5

In the video, you stated that the Administrator is the most traveled

Ms. Grooms.

I'm sorry.

Do you still agree with --

If we're going to use video clips, I think now would be a

good time to have a conversation about the video itself.

6

Ms. Holmes.

7

[Discussion off the record.]

8

Ms. Holmes.

We can go back on the record and you can state your objection.

9

Ms. Grooms.

Yeah.

Okay.

Can we go off the record for a minute?

So our objection is to the fact that the -- so obviously he

10

was recorded without his consent over a period of many hours on a series of two

11

different dates.

12

an argument that is misleading but also just not helpful to context.

13
14

The video itself is cut and pasted together in a intentional way to make

And so asking him questions about the video out of context, we think, is only
really furthering the misleading nature of the video itself.

15

If you have a copy of the video, which I understand you don't have the full video,

16

we'd be happy to watch and discuss the full video with you and then be able to

17

understand what actually occurred in context.

18
19

But we have concerns about sort of quoting from the video and asking about sort
of specific lines from the video.

20

But he is happy to talk about what he understands to be things that actually do

21

occur at the SBA and actually have occurred at the SBA, and his work at the SBA.

22

already explicitly stated that he made many misstatements on the video.

23

some.

24

have stated if not for trying to impress a date, and are not accurate to the way that the

25

SBA works and the sort of functions of the SBA.

He has

He listed out

I think it's fair to say there are others that he feels he misstated or would not

And we're happy to come back to you


32

1

with like a longer list of that, if that is helpful, and certainly happy to have him answer

2

questions about what actually does occur at the SBA.

3

I think the video itself, though, is hard to discuss in sort of spliced-out detail.

4

Ms. Holmes.

And your objection is noted.

I would just note that it's actually

5

not a valid objection under the House rules or the committee rules, unless you have a

6

specific privilege you're trying to invoke over the video.

7

Ms. Grooms.

So the video is out of context and misleading.

So in the rules of

8

evidence, there would be, you know, a rule of completeness.

9

evidence don't occur to actually apply here, but the principles behind them are the same,

10

the idea being that, you know, the information that you would get from this is not

11

complete without more information, which you don't have, right, because whoever put

12

out this video intentionally put it out without the full context of the many hours of this

13

date.

Obviously, the rules of

14

If you're going to sort of insist upon asking him questions about the video, I think

15

our request is that you show him at least clips of the video that you're showing so that he

16

can sort of see it in context, and we will see what he is able to remember about the video.

17

But what I'm saying is, you know, he has acknowledged that it was incredibly

18

embarrassing to him.

19

and he said things to just make his date, you know, happy, and that she was aggressively

20

pressing, as you can sort of see in the video, she was aggressively pressing and he said

21

things to sort of move the conversation along.

22
23
24
25

He has acknowledged that he said things that were just wrong,

And I think to the extent that there are things about the SBA that is different than,
or things that you're interested in, I think all of those things were misstatements, right?
Like, essentially all of the things that the committee has expressed interest in
investigating related to the SBA are things that are not related to how he actually


33

1
2

understands the SBA to have worked, so -Ms. Holmes.

Okay.

So, again, like I mentioned, we don't follow the rules of

3

evidence, and we did say that -- agreed to the scope that the video was going to be part

4

of the scope in this conversation.

5

I understand that you have already made what you feel is a statement.

6

free to answer questions or not, but absent an actual assertion of privilege or something

7

that is recognized under the House rules or the committee rules, we do intend to proceed

8

with questions.

9

You are

Now, I will remind you that you are here voluntarily, and you do not have to

10

answer these questions.

11

back and have you testify at a deposition instead to answer these questions.

12

while, you know, I understand that dating is hard in this city -- we've all been there, it's a

13

horrible world out there -- it is within our duty under the Constitution to investigate

14

allegations made about the SBA and to have you come in and correct the record and

15

provide context.

16

However, you do still have a subpoena that we could bring you
Because

You are free to provide as much context to these statements that you want.

In

17

the interest of reducing embarrassment, I was not going to play the video.

18

going to say things.

19

helpful for you in remembering, we can go that route, or we can do what I said was the

20

raw transcript that we typed up based off of the video.

21

I was just

However, if you believe that the video being played would be

If you want to confer with your counsel, that's fine.

22

a second so you guys can chat.

23

Ms. Grooms.

24

[Discussion off the record.]

25

Ms. Grooms.

Yeah.

Let's go back on the record.

We can go off the record for


34

1
2

To be clear, Mr. Robinson did not make any allegations on the video.
things, whether they were -- and he said many of them weren't accurate.

3
4

He just said

I think the preference is just if you could play the part of the video you're asking
about, and then he will try to assist you in providing more context to that.

5

Ms. Holmes.

Okay.

And if you want to just talk about general ideas that were

6

discussed, like, we can start there.

7

go into the video, because I do not want to subject your client to unnecessary emotional

8

harm.

9

Ms. Grooms.

10

And then if we have more specific questions, we can

Appreciate that.

BY MS. HOLMES:

11

Q

So let's just start with, you said the Administrator travels about once a week,

13

A

Correct.

14

Q

-- on average?

15

Do you think that makes her one of the more traveled members of the Cabinet?

12

right --

16

Whether or not it's the most traveled or least traveled, do you think that she travels more

17

than the average Cabinet member?

18

A

Yes.

That statement that I made in the video that she was the most

19

traveled member was through rumor mill.

20

much each Cabinet member travels.

I do not have the exact numbers of how

21

As far as I can recall, it was through discussing the travel of other Cabinet

22

members with other staffers that we made the assumption that she was the most

23

traveled.

24

Q

25

So that's -- I do not know if that is a factual statement or not.
Okay.

You said you traveled with her a minority of the time.

So about

how many trips did you travel per week or per month with the Administrator?


35

1
2

A

As to my best knowledge, during my entire tenure at the SBA so far, I have

done less than 10 trips with the Administrator.

3

Q

Okay.

4

A

No.

5

Q

Okay.

6

[Discussion off the record.]

7

Did you ever travel with the deputy administrator?

BY MS. HOLMES:

8

Q

9

that right?

10

A

Yes.

11

Q

And does she decide what staff come with her?

12

A

I do not know the process of assigning staff.

13

Q

Do you know who assigned you to trips?

14

A

I was assigned by the -- for every trip I took, I was assigned by the director of

15

You said the Administrator gets to decide where and when she travels.

advance to advance those trips.

16

Q

So all the trips you did was just advance?

17

A

Correct.

18

Q

Okay.

19

A

No, they were just as an advance role.

20

Q

In the video you responded "yeah" to the question of whether

You didn't do any logistical support at the event?

21

Administrator Guzman said she's basically campaigning for President Biden in critical

22

battleground States.

23
24
25

You mentioned in your statement that that was not something you agree with
today.

Is that true?
Ms. Grooms.

I think that was a little confusing.

Is


36

1

Ms. Holmes.

Too specific?

2

Ms. Grooms.

It was, frankly, just confusing.

3

Ms. Holmes.

Yeah.

4

Administrator Guzman said basically you're going to these critical battleground

5

Okay.
Do you want to rephrase?

States.

6

You responded, yeah.

7

The undercover reporter says, to basically campaign for President Biden?

8

You respond, yeah.

9

I understand there might be some splicing and dicing in there, but do you

10
11
12
13
14

Sorry.

remember making anything like that statement?
Ms. Meers.

Can we take a pause?

I heard you say "Administrator Guzman

It was -- yeah, sorry.

Open quote, Administrator Guzman said

said," and -Ms. Holmes.

basically we are going to these critical battleground States.

That was -- end quote.

15

Ms. Harrington.

16

Ms. Holmes.

17

Ms. Harrington.

18

Ms. Holmes.

Yes, the undercover reporter.

19

Ms. Meers.

Clarify Administrator Guzman did not say --

20

Ms. Holmes.

Correct.

21

An open quote from the journalist, Administrator Guzman said basically we're

22

going to these critical battleground States, end quote, from the undercover reporter.

Who said that, Lauren?

From the undercover reporter.
So it was the unidentified person that said that?
And then --

No, it was -- sorry.

23

Then Mr. Robinson responds, quote, yeah, end quote.

24

The journalist finishes with, open quote, to basically campaign for President Biden,

25

end quote.


37

1

And Mr. Robinson responds, quote, yeah, end quote.

2

Ms. Grooms.

Okay.

How about this, tell her, to the best of your recollection,

3

do you ever remember Administrator Guzman ever saying anything to the effect of, we

4

need to travel to battleground States?

5

Mr. Robinson.

Yes.

The quotes on the video are accurate, and that is correct, I

6

never heard the Administrator express the need to travel to any State for a particular

7

reason.

8

Ms. Grooms.

I'm sorry.

9

Mr. Robinson.

Oh.

10

Ms. Grooms.

My question to you was, did you ever hear Administrator Guzman

Mr. Robinson.

No, she -- the Administrator never said those words quoted in the

Ms. Grooms.

And so is that an example of one of the misstatements that you

16

Mr. Robinson.

Correct, yes.

17

Ms. Holmes.

Okay.

And that was just to impress or move the person along at

Yes.

I cannot say the exact reason I said something that was not

Okay.

So if not from the Administrator herself, do you remember

11

say --

12
13

video.

14
15

18
19
20
21

That was slightly confusing.

made?

the date?
Mr. Robinson.
factual.
Ms. Holmes.

22

where you got the idea that the goal was to go to battleground States or why you would

23

say anything to that nature?

24

Ms. Grooms.

25

Yeah.

So that's not exactly what he said even in the video.

maybe if you could just explain, do you believe that the goal of the SBA is to travel to

So


38

1

battleground States?

2

Mr. Robinson.

No.

The goal of the SBA is not to travel battleground States.

3

The political importance of a event -- or excuse me -- of a region is never, as far as I can

4

recall, never considered as a reason to go -- to go to an event or say no to an event.

5

BY MS. HOLMES:

6

Q

So when you were explaining how you decide what events to go to, in the

7

third category you mentioned that it was whatever priorities of the SBA or the

8

Administrator at the time.

9

where there are battlegrounds?

Her priorities have never been aligned with going to States
That was never discussed at any of those meetings?

10

A

No, I do not believe so.

11

Q

Okay.

To clarify that for the record, in all of the meetings about events and

12

which ones you were selecting, the Administrator, or anyone in the room, never said that

13

they were going to go to battleground States?

14

A

To my best recollection.

15

Q

Okay.

17

A

I mean, this is my personal opinion --

18

Q

Yes, yeah.

19

A

-- on to what a battleground State is?

16

To your recollection and/or knowledge, what are battleground

States?

A battleground State is a State that is

20

important for any candidate in the Presidential election to win in order to go on and win

21

the election.

22

Q

Do you know what the battleground States are for this upcoming election?

23

A

I have a general knowledge, but I actually do not know what are the

24
25

confirmed battleground States of either campaign.
Q

What do you generally think the battleground States are for the Democrat


39

1

campaign?

2
3

A

North Carolina, and Georgia.

4
5

Q

Did you ever go, in your travels with the Administrator, to any of those

States you just named?

6
7

Historically, they have been States like Pennsylvania, Michigan, Arizona, and

A

Yes.

I have been to Pennsylvania with the Administrator and I have been to

Michigan with the Administrator.

8

Q

Is that just one time each or how many?

9

A

To my best recollection, it was just one time each.

10

Q

One time each.

11

And that was for events?

12

A

Correct.

13

Q

Do you remember the dates of those events -- or around the general time?

14

A

The -- as far as I can remember, the Pennsylvania trip that I went on with the

15

As an advance staff.

Administrator was earlier this year, I believe in March.

16

Q

Okay.

17

A

The trip to Michigan I believe was sometime in 2023.

19

Q

Okay.

20

Okay.

18

21

I have no clue the

month.
That's okay.

So let's deal with the Pennsylvania one.

You said earlier in March.

Other than the Administrator, who else was at that event?

22

A

23

media staffer --

24

Q

Okay.

25

A

-- and members of the security detail.

To my best knowledge, we had our press secretary, there was the digital


40

1
2

[11:03 a.m.]

3

BY MS. HOLMES:

4

Q

Were there any representatives of the State there?

5

A

No.

6

Q

Were any Members of Congress there?

7

A

No.

8

Q

To the best of your recollection, what was the event about?

9

A

The Administrator did multiple events that day.

The first event was a small

10

business visit and announcement of government funding to the City of Scranton, and the

11

following number of events were all small business visits.

12

Q

13

Ms. Grooms.

14

Okay.

Q

16

SBA individuals?

17

crowd.

19

Could you be more specific?

Do you mean from the SBA, or --

BY MS. HOLMES:

15

18

Who was at the announcement for Scranton?

A

Who was participating in the event, whether they were State individuals,
Who spoke at the event?

I don't need to know attendees, like, in the

Part of the event was the Administrator, the mayor of Scranton, and the

White House Director of Intergovernmental Affairs.

20

Q

And who is that?

21

A

Tom Perez.

22

Q

So those three were the ones that spoke, as far as you remember?

23

A

As far as I know.

24

Q

Okay.

25

A

I have no knowledge of why Scranton was chosen.

In your planning, do you remember why Scranton was chosen?


41

1

Q

Okay.

2

A

I do not.

3

Q

Okay.

4

A

As I can recall, unfortunately, those events were planned rapidly.

5

Q

Okay.

6

A

Within a week.

7

Q

Okay.

8

A

I have -- I believe it was just because we received the invitation on short

Q

Okay.

9
10
11

When was your meeting about this event?

Do you remember?

Do you remember about how long it took to plan this one?

Why so fast, if you can remember?

notice.
Did you receive the invitation either in your box or in that general

box that we talked about at the beginning?

12

A

I am not sure how the invitation came in.

13

Q

You're not sure or you don't remember?

14

A

I am not sure.

15

Q

Okay.

16

A

As far as I can recall, it would have been after the event was confirmed.

17

Q

Okay.

18

A

Correct.

19

Q

You just did day before?

20

A

Yes.

21

Q

Okay.

22

A

Due to the nature of my role, I had no -- generally, no input into events

23

When did you first hear about the event?

So this wasn't one that you handled, for lack of a better term?
I had no responsibility in planning this event.

Were there often events you had no hand in planning?

unless, as I mentioned earlier, it was those few events I worked with public engagement.

24

Q

25

traveling?

Do you remember how many days heads-up you got that you were
Was it, like, day of that they were like, "Oh, hey, you need to go do the


42

1

day-before planning"?

Was it just a couple days before?

2

A

For my personal travel?

3

Q

Yes.

4

A

As far as I can remember, I was told probably 4 days ahead of time.

5

Q

Four days?

6

And how did you travel?

7

A

The SBA pays for all of my work travel.

8

Q

Okay.

9

A

Yes.

10

Q

Okay.

11

For you getting there.

Okay.
Do you pay for it or does SBA?

Do you have to keep logs or anything of what you spend?

What do those look like?

What kind of information do you have to

put on those when you travel on official travel?

12

A

To my best recollection, it is the cost of travel, whether that's renting a car

13

or traveling by air, the hotel fees, the per diem amounts, and if there is any additional

14

fees.

15
16

Like, sometimes we have to pay for parking at hotels or things of that nature.
Q

So do you put those on your credit card and get reimbursed, or does the SBA

have a direct expense account that they pay it through?

17

A

I have a government credit card.

18

Q

Okay.

19

A

Yes.

20

Q

Okay.

To the best of your recollection, at this event, did you speak with

Yes.

I spoke prior to the start of the event and each subsequent event just

21
22
23

Do you still have that?

Mr. Perez?
A

explaining the movements of the event.

24

Q

Like, the schedule, the timeframe, things like that?

25

A

Correct.

It would have been "walk here" and that sort of thing.


43

1

Q

2

advance with you?

3

A

I was there with members of the security detail.

4

Q

Just the security detail?

5

A

Correct.

6

Q

So Mr. Rodriguez?

7

A

Mr. Rodriguez was not on that trip.

8

Q

Okay.

9

A

Yes.

10

Q

Okay.

11

A

Correct.

12

Q

Okay.

13

A

As far as I remember, the main event and purpose for going was for a Small

14

Okay.

To the best of your recollection, what other SBA staff were doing the

But his team?

You said you went to Michigan as well sometime in 2023?

What do you remember about that trip?

Business Digital Alliance event.

15

Q

Okay.

16

A

And then, following the SBDA event, the Administrator visited with two or

17

three small businesses.

18

Q

Did you go to those small businesses, too?

19

A

Yes.

20

Q

Do you know how those small businesses were chosen?

21

A

As far as I know, in the general practices, it is -- the small businesses are

22

chosen by the SBA district office.

23

Q

Okay.

24

A

I'm sorry.

25

Q

That's okay.

For Michigan, who runs that office?
I can't remember her name.

Do you remember?


44

1
2

Were there any Members at that one?

Members of Congress -- excuse me -- at

that event in Michigan?

3

A

I do not believe so.

4

Q

Okay.

5

A

To the best of my knowledge, no.

6

Q

Okay.

Were there any State officials?

And what did that event look like?

7

with the Small Business Digital Alliance.

8

discussion, a meeting, or was it a public-facing event?

9

A

10

the event with.

11

event.

12
13

Q

Was that a presentation?

I cannot remember which partner organization was represented at that

Okay.

You mentioned in your opening statement that the stuff about

Montana was untrue that you said in the video.
A

Correct.

15

Q

Okay.

Is that right?

And you said that you have no recollection and/or knowledge of the

SBA going to Montana for political purposes?

17

A

Correct.

18

Q

Okay.

19

A

Just to clarify, the trip to Montana did happen.

20

Q

Okay.

21

A

The trip was not based on political reasoning.

22

Was that a

It was a fireside chat with a member of the organization that we were doing

14

16

You said there was something

Do you remember -- yeah, go ahead.

The trip was to highlight the

work of Montanan small business owners during National Small Business Week.

23

Q

Okay.

24

A

The event was this year.

25

Q

This year.

This year or last year?

So small business week was in March?


45

1

A

It was the end of April, beginning of May.

2

Q

Okay.

3

A

I was not.

4

Q

Okay.

5

Ms. Grooms.

6
7

Okay.

And you were not on that trip, though?

This is a room where we would definitely know when National

Small Business Week is.
Ms. Holmes.

8

I've had, like, 97 strokes since then.

BY MS. HOLMES:

9

Q

So the trip occurred.

10

A

Yes.

11

Q

Okay.

12

A

I have no knowledge of who went on that trip other than the Administrator.

13

Q

Okay.

Was the Administrator on that trip?

To the best of your recollection, who else went from the SBA?

But you knew that it was to campaign for small businesses -- or to

14

advocate for small businesses in Montana?

15

Freudian slip.

16

A

17

Correct.

I will strike "campaign."

The main purpose of the event was to attend the national -- or

Montana's National Small Business Week award winners.

18

Q

19

How do you know that that was the purpose of the trip?

20

A

21
22
23

That was a

Award winners.

Okay.

That was the purpose of every trip we did that week, was visiting a State and

the Administrator being present for their award ceremonies or to highlight those winners.
Q

Okay.

Within that week, how many other States are you aware of that she

traveled to for that purpose?

24

A

To my best knowledge, it was three other States.

25

Q

Do you remember which ones they were?


46

1

A

2

cannot remember.

3

Q

The Administrator went to Wisconsin, Colorado, and then the other one, I

Okay.

It was a New England State.
How did you know that the purpose -- how did you know what the

4

purpose of these trips were?

5

in the briefing book?

Did someone tell you?

6

A

I was part of the trip planning calls.

7

Q

Okay.

8

Ms. Harrington.

9

Ms. Holmes.

10

Lauren, we have 1 hour.

of questioning, and then we will take a break.
Ms. Harrington.

12

Ms. Holmes.

Okay.

Yes.

And do we get the same at the end in ours?

You can have your hour plus whatever it takes to finish your

13

line of questioning, as I stated in the beginning.

14

BY MS. HOLMES:

16
17
18

Did you put it

I have 2 minutes left according to my clock, but I will finish this line

11

15

Was it an email?

Q

Thank you, Ellen.

So you said you were a part of the trip planning for those events specifically,

or is that part of your role more generally sometimes?
A

In general, I tried to make at least one trip planning call just so I could

correctly assign briefing material.

19

Q

Okay.

20

A

Correct.

21

Q

Who was on those calls?

22

A

There are quite a few people on those calls.

23

Q

Okay.

24

A

In general, if it is a trip to a district, those calls are hosted by the district

25

So was that for all travel that she did?

office, and then they include a good number of SBA staff from Headquarters.


47

1

Q

Okay.

2

A

That's -- yeah, that's generally who was involved.

3

Ms. Holmes.

4

[Recess.]

5

Ms. Harrington.

Anyone else that you can remember?

Okay.

We can go ahead and go off the record.

Hi, Tyler.

I'm Ellen Harrington, the deputy staff director with

6

the House Small Business Committee, and I want my colleague to take a minute to

7

introduce herself to you.

8
9

Ms. Beca-Barragan.

Hi, Tyler.

I'm Renata Beca-Barragan, senior counsel for the

Small Business Committee, minority side.

10

Ms. Harrington.

11

Is there anything that you would like to say to clarify from the previous hour?

12

Mr. Robinson.

Thank you for being here today.

Yes.

We appreciate it.

I just want to put on the record and note that, in the last

13

hour, Ms. Holmes asked what my opinion -- or, in my opinion, what the battleground

14

States were for this year and if I had traveled with the Administrator to any of those, and I

15

said I had been to Pennsylvania and Wisconsin.

16

Georgia, with the Administrator.

17

Ms. Harrington.

18

Okay.

Just to add, I was on a trip to Atlanta,

And that's it.
Thank you very much.

I appreciate it.

BY MS. HARRINGTON:

19
20

Q

21

the video today.

22

was secretly reported by an unidentified person who targeted you through a dating app.

23

Then, it was diced and spliced to try to infer wrongdoing with the administration.

24
25

I first just want to start off by expressing some of the concerns we have with
We have concerns with the use of this -- the reliance of this video.

It

We have concerns that this video was produced by James O'Keefe, the founder of
Project Veritas, who was ousted from the organization in 2023 over allegations that he


48

1

mistreated workers and misspent organization funds.

2

of his previous work.

3

on a Pennsylvania postal worker's allegations of election improprieties, and Mr. O'Keefe

4

and the organization had to admit there was absolutely no wrongdoing and no voter

5

fraud at this Erie post office.

6
7

We also have concerns with some

He had to settle a lawsuit resulting from the group's videos based

Tyler, are you aware that Mr. O'Keefe profits off these malicious operations and
reportedly pays swipers $5,000 if they use the footage?

8

A

Yes, I am aware of that.

9

Q

Okay.

So, again, we have concerns that the majority is relying on this

10

online video manufactured by an individual whose credibility has been permanently and

11

irreversibly damaged, and we're concerned that the majority is using taxpayer dollars to

12

discuss this heavily altered video designed to imply wrongdoing.

13
14

So let me begin.

I just want to summarize some of the statements that you

made, so -- and I just want to make sure I fully understand your role at SBA.

15

In your role as a special advisor, you prepared the Administrator's briefing book

16

and conducted research as necessary, but you did not make final decisions as to where

17

the Administrator travels, who travels with the Administrator, and who gets invited to

18

those events, correct?

19

A

Correct.

20

Q

Okay.

21

A

Correct.

22

Q

Okay.

To be clear, you do not have a decisionmaking authority, correct?

Okay.

Understanding that you do not have this decisionmaking

23

authority, what criteria do you and the scheduling team use in making travel

24

recommendations?

25

A

As I mentioned earlier, it is -- first, what is the Administrator's availability at


49

1

the requested time?

2

And then the final is if it aligns with the priorities and policies that the SBA is trying to

3

promote at that moment.

Then it is if it is something that is at the Administrator's level.

4

Q

5

In your experience, has the scheduling team stated the need or desire to travel to

6

Okay.

So you've listed this criteria.

a battleground State to campaign for the President, and is that a factor?

7

A

No.

9

Q

Okay.

10

I want to turn to this videotape, unfortunately.

8

11

I do not recall that ever being discussed, and I do not believe it is a

factor.
Thank you very much, Tyler.

I appreciate that.

about, if that's okay?

12

A

Yes.

In March 2024, I matched with someone on a dating app, and we

13

began texting on that app and then on our cell phones.

14

place about a week later.

15
things.

17

both dates without my knowledge or consent.

19

We arranged a date that took

On that date, we -- you know, it was around an hour.

16

18

Could you tell us how it came

We talked about various

I now know that she was not who she said she was and that she was recording

And then, after the first date, we arranged a second one that took place -- kind of
a similar timeframe -- 7 to 10 days later.

And then --

20

Q

How long was that date?

21

A

It was also around an hour.

22

Q

So about 120 minutes total of --

23

A

Correct.

24

Q

Okay.

25

A

I believe the video is 18.

A little over, probably.
Okay.

And the video was 12 minutes?


50

1
2

Q

Okay.

But in the terms where you're being -- without the editorial by

James O'Keefe, it was 12 minutes, I believe.

You may not know that.

3

A

I do not know.

4

Q

I did double-check that a couple times.

5

Okay.

6

A

Correct.

7

Q

Did she say where she was employed?

8

A

She told me that she was a private tutor for high school students.

9

Q

Do you think this is real, or do you think it's fake?

10

A

I do not believe she is a private tutor for high school students anymore.

11

Q

Okay.

12
13
14
15

Do you recall the name of the person -- you said it was Grace?
She told me her name was Grace.

Okay.

Okay.

And how did she describe herself in these

exchanges?
A

I mean, she described her occupation, her family background.

She

did -- we did talk about politics and our interests outside the things we do.
Q

Okay.

And, based on your previous testimony -- I just want to be

16

clear -- did you at any point go along with her statements or talk about things that you

17

really don't know a whole lot about during these dates to impress her?

18

A

19

knowledge of.

20

Q

Yes.

Okay.

During both dates, I said things that are untrue and that I have no

I assume this isn't easy for you to admit today, and I'm sure, though,

21

you're not the first person and you're probably not the last that tried to impress someone

22

on their date.

23
24
25

So thank you for being forthcoming.

I just want to follow up, if you don't mind.

We appreciate that.

How and when did you find out about

being secretly videotaped?
A

The day the video was released, I was notified by our chief of staff that the


51

1
2

video was made public.
Q

Okay.

Okay.

So you had two dates.

3

Again, that's a total of 120 minutes-plus.

4

were 10 to 12 minutes, is what I recorded it at.

They lasted roughly an hour each.

And the videotape itself was -- your recordings

5

So this was heavily edited and manipulated, correct?

6

A

Yes, I believe so.

7

Q

Okay.

8

A

I feel some of them were, yes.

9

Q

Okay.

10

A

Personally, it is an embarrassment and something I deeply regret.

11

Professionally, it did cause -- it was hard for me to adjust at first after the video

12
13
14

And do you feel your words were taken out of context?

How has this video affected you professionally and personally?

was released with some coworkers knowing and some not.
Q

Okay.

Okay.

So, again, I haven't seen all the footage, and it sounds like

you haven't seen the entire footage as well.

15

A

16

dates altogether.

17

Q

I've seen the 18-minute video.

Uh-huh.

Is that correct?

I believe you said that.

I have not -- never seen footage of both

And we learned earlier today that the majority who called you

18

here today hasn't even seen the full uncut video.

19

being entered into the record and being used in the investigation.

20

Just 1 minute.

21

Actually, I do want to go back.

22

I'm sorry.

So, again, we have concerns about this

I do want to go back and just go

through some of the statements that were in the video.

23

From what I understand in your opening, you said this person portrayed herself as

24

a very strong Democrat, and it sounded like she thought you weren't doing enough to get

25

President Biden reelected.

So there seems to be -- there are rules against the use of


52

1

official resources for political campaign purposes.

2
3

In your experience, does the Administrator use official resources for political
campaign purposes?

4
5

A

In my experience, the SBA has never used resources for campaigning

for any person or cause.

6

Q

7

follow up.

8
9

No.

Okay.

Okay.

And there was a little discussion earlier, and I just want to

Specifically, did you ever hear the Administrator say they are going to
battleground States to basically campaign for President Biden?

10

A

No.

11

Q

And those were the words of the unidentified woman, not yours?

12

A

Yes, I believe so.

13

Q

Okay.

To the best of my recollection, she never said such things.

It appears you said, "Anytime we go and try to visit a Member of

14

Congress, if they're a Democrat" -- and then you say, "So we're going to Montana because

15

Senator Tester, and he's a Democratic Senator from Montana.

16

race.

He's in a tough election

That's, like, a seat we need in the Senate to maintain the minority."

17

Did you hear Administrator Guzman make that statement?

18

A

19

No.

I, to the best of my knowledge, never heard Administrator Guzman

make that statement.

20

Q

21

It appears you said --

22

Ms. Grooms.

23

Ms. Harrington.

24

Ms. Grooms.

25

Okay.

Thank you.

If we're going to do -- I'm sorry.
Okay.

If we're going to do the video, if you could show him the video.

think that was a request of the majority.

We have the same request here.

I


53

1

Ms. Harrington.

2

So we've gone through a number of your statements.

3

you prefer, we don't use -- I don't have access to the video quickly.

4

ahead and just move on from there, if that's okay.

5

Ms. Grooms.

Okay.

Okay.

Yeah, that's fine.

Thank you.

I will -- okay.

That's fine.

I had a couple more, but if
So why don't we go

Or if you want to have him -- as I said to the

6

majority, if you would like to ask him factual things about what occurs at the SBA, that's

7

fine.

8

If we just could avoid the statements -- the quoting from the record -Ms. Harrington.

Okay.

Okay.

So, I guess, under the Hatch Act, there are strict

9

rules as to what the Administrator can and cannot do.

10

referring back to the video where the narrator said "indirectly campaigning."

11

Administrator does not -- we'll scratch that statement.

And I guess I want to -- I'm
The

We'll scratch that.

12

Okay.

13

Ms. Grooms.

14

Ms. Harrington.

15

[Discussion off the record.]

16

Ms. Grooms.

17

In the first round, Mr. Robinson, you described battleground States that you

18

described, in your personal opinion, were battleground States and that the Administrator

19

had traveled to, and I think you described which ones you had gone to.

20

correct it in the second round.

I'm fine with questions.
Okay.

That's good.

Can we have one moment?

Yes.

If we could just go back on and we can just clarify something.

You tried to

21

Can you just clarify which of the States that, in your opinion -- personal

22

opinion -- are battleground States that the Administrator has traveled to have you also

23

traveled to?

24
25

Mr. Robinson.

Yes.

Of those States, I have traveled with the Administrator to

Pennsylvania, Michigan, and Georgia.


54

1
2

Ms. Grooms.

Uh-huh.

Wisconsin?

3

Mr. Robinson.

No.

4

Ms. Grooms.

Okay.

5

And have you traveled with the Administrator to

it wrong.

Okay.

Sorry.

I'm not sure if that was unclear or not, but I heard

Thank you.

6

Ms. Harrington.

7

Lauren, do you plan to go into another hour?

8

Ms. Holmes.

9

Ms. Harrington.

10

hour.

We're okay.

Okay.

Thank you.

Uh-huh.
You do.

Okay.

We'll have some questions, then, for the next

We're good.

11

[Recess.]

12

Ms. Holmes.

13

I would just like to note at the top, in response to the minority's claims that we are

14

not saying anything about the validity of the video or not, that we do have a constitutional

15

duty to investigate any allegations made against and/or about the SBA because we are in

16

charge of overseeing the SBA, and that is why we are here today.

We can go back on the record.

17

I think if the roles were flipped, the minority would be doing the same, and,

18

honestly, they would be derelict in their duty if they did not investigate serious allegations

19

such as these against the SBA.

20

Ms. Sawyer.

So --

Can I just pause you there just for a moment?

Because I just do

21

want to make clear on the record that whatever allegations are being made or have been

22

made are not coming from Mr. Robinson.

23

allegations, but he does not.

24

the committee, the committee majority -- but Mr. Robinson himself has never made

25

allegations of wrongdoing against the SBA.

You can ask him directly if he has any

I understand that you all may have allegations -- meaning


55

1
2
3

So I'm more than happy having you ask him that directly, but you -- I just want to
make clear on the record that there are not allegations coming from Mr. Robinson.
Ms. Holmes.

And I will just clarify.

For your awareness, allegations -- when I say

4

"allegations," I'm meaning statements that he made and/or agreed to on the video that

5

was released.

6

allegations made in that video about wrongdoing at the SBA, whether he confirmed those

7

statements by someone else or whether he made those statements himself.

Those are the allegations that we are discussing.

And there were

8

So that's the -- when I say "allegations," that's what I'm discussing.

9

Ms. Sawyer.

10
11
12
13
14
15

Understood.

So what would be very helpful is if you could identify

the allegation and the wrongdoing and ask him now if that has occurred at the SBA.
Ms. Holmes.

So that was my intent, and your team said that we didn't want to go

through line by line of the video because it would -Ms. Sawyer.

But, if there are underlying allegations from what's in the video, I

assume you can ask him about those.
Ms. Holmes.

16

Okay.

Then we'll go ahead and add those back into our next hour.

BY MS. HOLMES:

17

Q

18

Just to provide a little bit of clarity around the trips that we had discussed, we

But, first, let's start where we left off.

19

discussed one in Pennsylvania and then one in Michigan.

20

and we'll get to that in a second.

21

You added the one in Georgia,

But, for each of those trips and all the other trips that you worked on, there was

22

an initial meeting -- which you described the attendees at -- that you would decide

23

whether or not this event or invitation would be accepted and the Administrator would

24

attend, right?

25

A

That was one meeting that occurred?

Correct.


56

1

Q

And then you mentioned near the end of our hour that there was a second

2

trip planning meeting.

3

on the Administrator's calendar, there was a second meeting?

4

Ms. Grooms.

Is that right?

Once the trip was decided that it was going to be

Just to clarify what he said, he did not say that the group decided

5

to put it on the Administrator's calendar.

6

decided to make a recommendation to the Administrator.

7

Ms. Holmes.

8

I think he said that the team that met initially

Okay.

BY MS. HOLMES:

9

Q

For the second meeting that occurred after the Administrator decided to put

10

something on her calendar or not, it was a trip planning meeting which you said included

11

people from HQ and then district offices, right?

12

A

Correct.

13

Q

To the best of your recollection, who from Headquarters would be in those

14

meetings?

15

A

To my best knowledge, it would be members of the communications team,

16

members of our HQ field staff, members of the public engagement team, and then myself

17

and the directors of scheduling and the directors of advance.

18
19
20
21

Q

Okay.

Were the chief of staff or deputy chief of staff ever involved in

A

To my best knowledge, they are invited, but I do not recall if they attended

those?

that specific -- those specific meetings.

22

Q

Because this was more of the granular, like, logistics planning, right?

23

A

Correct.

24

Q

Okay.

25

A

Once again, to the best of my knowledge, they would be included, yes.

Did it include subject-matter experts on the topic of the trip?


57

1

Q

Okay.

3

A

10 or less, yes.

4

Q

10 or less.

5

How many were in Georgia?

6

A

To my best recollection, there was just one.

7

Q

One to Georgia.

8

Do you remember when that was?

9

A

That trip was earlier this year in February, I believe.

10

Q

And I have just one more clarifying question from the discussion with the

2

11

You said you went on probably a total of 10 trips in your tenure,

right?

Okay.

Democrats.

12

What day did Mr. Plews call you about the video?

13

A

He called me the day the video was released.

14

Q

Day of?

15

A

Yes.

That evening.

16

Q

Okay.

Did he mention if he had advanced knowledge of the video?

17

A

Did he mention if he had advanced knowledge?

18

Q

Uh-huh.

19

A

No.

20

Q

Okay.

21

Ms. Holmes.

22
23
24
25

Okay.
We're going to go through a couple of the press releases from the

events, which we will be introducing as exhibits.

So we'll go one at a time.

Let's start with the one to Scranton because that was in February.
introduce that as majority exhibit 1.
[Robinson Majority Exhibit No. 1

So we'll


58

1

was marked for identification.]

2
3

Ms. Holmes.

And we'll collect all these at the end, just for everyone's awareness.

So please do not take them out of the room.

4

Okay.

5

BY MS. HOLMES:

6

Q

So what's been marked as majority exhibit 1, this is the press release

7

published on February 27th, 2024, about Administrator Guzman going with Mr. Perez and

8

Scranton mayor for the visit that we had discussed earlier.

9
10

Well, I guess, first, to the best of your recollection, is this the trip you were talking
about that was in early 2024 to Scranton?

11

A

Yes, ma'am.

12

Q

Okay.

13

A

No, I have not.

14

Q

Okay.

15

Have you ever seen this press release before?

Did you ever see press releases from your events after they

happened?

16

A

In general, no.

17

Q

How come?

18

A

I don't have a specific reason, I guess.

19

Q

That's okay.

20

Okay.

I do not look at SBA press releases.

Yeah.

I was just curious.

So, in this, if you could flip to the second page, it says, quote, "Today, SBA

21

Administrator Isabel Casillas Guzman traveled to Scranton, Pennsylvania, where she

22

joined Mayor Paige Cognetti and White House Senior Advisor and Director of

23

Intergovernmental Affairs Tom Perez to announce more than $540,000 in new grants to

24

local small businesses by the city of Scranton through funding in the American Rescue

25

Plan."


59

1

Do you remember prepping for or discussing the American Rescue Plan in all of

2

your preparations for these events when -- do you remember talking about the American

3

Rescue Plan and the funds going to Scranton?

4
5
6
7

A

Just in the context that that was -- the main purpose of the event was to

highlight this new announcement.
Q

Okay.

Did any Republican Members join this trip, as far as you can

remember?

8

A

As far as I can remember, no.

9

Q

In our initial scheduled transcribed interview, Mr. Representative Meuser

10

from Pennsylvania mentioned that he lives 5 minutes from this event and did not receive

11

an invite.

12

Do you recall why or why not Members were not invited to this event?

13

A

I have no knowledge of why Members are invited and when they get invites.

14

Q

Do you know who does make that determination?

15

A

The SBA's Office of Congressional and Legislative Affairs.

16

Q

And you said, to the best of your recollection, no Democrat Members

17

attended either?

18

A

Correct.

19

Q

Okay.

20

All right.

Is this the kind of event you were talking about when you

were talking about events in the video?

21

A

I believe this trip is mentioned, yes.

22

Q

To the best of your recollection, what did you say that was true or not true

23
24
25

about this trip in the video?
A

To my best knowledge, I said in the video that we were going to announce

this money and that -- I believe in the video I had misstated that -- or, you know, said


60

1

something that was untrue that the White House directed us to go or we were going

2

because the White House told us to.

3

House, but there was no demand that we go to this event.

4

That's not true.

And I do not recall if it is mentioned during the video about inviting Republican

5

Members or inviting Democratic Members only.

6

happened.

7

inviting any Members.

8
9

We were invited by the White

Q

Once again, that conversation never

There was no discussion about -- as far as I'm aware, no discussion about

Okay.

It was not part of my job.

And, from either personal or professional knowledge, Scranton,

Pennsylvania, is the hometown of the current President, Biden.

10

A

Correct.

11

Q

Okay.

12

Ms. Holmes.

Is that correct?

I believe he was raised there.

I'm going to do the next press release, which we will mark as

13

exhibit -- majority exhibit 2, which is the other trip we talked about in the prior hour from

14

2023 to Michigan.

15

[Robinson Majority Exhibit No. 2

16

was marked for identification.]

17

BY MS. HOLMES:

18

Q

19

Michigan in 2023.

20

A

It does not.

21

Q

You were not on this one.

22

For the record, I will introduce the exhibit, anyway.

23

press release published on June 9th, 2023, entitled "Friday:

24

Officials to Visit Detroit."

25

Okay.

You said that you couldn't quite remember when you went to
Does the June timeframe sound about right?
This trip that exhibit 2 describes, I was not on.

So you were not on this trip.

Okay.
This is exhibit 2.

It is a

Biden-Harris Administration

You were on a different trip to Michigan in 2023?


61

1

A

Correct.

2

Q

Okay.

3

A

To my best knowledge, I would have been on at least one of the trip calls,

5

Q

Okay.

6

A

Just to clarify, there are more than one trip call for any trip.

7

Q

Okay.

8

A

But, yes, I would have been on one of those trip calls.

9

Q

Which one would you have been on?

10

A

The calls planning the event after it was decided that the Administrator

11

would go to it.

12

Q

4

13

Did you do the initial trip meeting for this event?

yes.
One but not both?

Okay.

You wouldn't have been on that initial one when the Administrator

is deciding what's going to be on her schedule or not?

14

A

Yes.

I would have been on that call as well.

15

Q

Okay.

On that one and then the planning meeting?

16

A

Yes.

17

Q

Okay.

18

Ms. Grooms.

19

[Discussion off the record.]

20

Mr. Robinson.

21

I think -- hold on a second.

Yeah.

Just to clarify, like, the meeting cadence --

BY MS. HOLMES:

22

Q

Yeah.

23

A

-- because I did describe it earlier.

24
25

the staff does the going through the invites.
Q

Uh-huh.

There is a meeting once a week where


62

1

A

I am on that call.

2

Q

Okay.

3

A

There is a meeting then following that meeting on the same week.

4
5

That is

the meeting where the Administrator confirms or passes on events.
And then, for any event or trip, once that trip is confirmed, there will be multiple

6

trip calls to plan out the schedule and the details of those events.

7

would have been on one of the trip calls, I was referring to those calls.

8

Q

9

of your knowledge?

Okay.

And, when I said I

About how many trip calls per event do you think occur, to the best

10

A

It generally varies.

11

Q

Okay.

12

A

Most of the time, there's probably three or four.

13

Q

Three or four?

14

The ones that have four or the larger number, are those ones that are just more

Okay.

15

logistically challenging?

16

the SBA decide how many meetings occur during that trip, to the best of your knowledge?

17

A

Yeah.

More important?

How do you decide -- not you.

How does

I believe it is, in general, due to the nature of the trip that -- whether

18

it is a lot of back-and-forth between what's involved in the trip or how long in advance we

19

have to plan the trip.

20

meetings just to make sure everything is solid.

21
22
23
24
25

Q

Okay.

If we have a longer time period, we'll generally have more

And I can't quite remember.

I apologize.

You're going to have to

remind me.
Which trip did you say you had a week to plan?

Was that the Scranton one, or

was that the Michigan one?
A

I believe I was referring to the Scranton trip that we had less than a week to


63

1

plan.

2

Q

3

Ms. Grooms.

"This trip" being?

4

Ms. Holmes.

Sorry.

5

Mr. Robinson.

I do not.

6

Okay.

Do you remember about how long this trip had lead time?

The June 2023 to Michigan.

BY MS. HOLMES:

7

Q

8

Ms. Grooms.

Again, the Exhibit 2 trip?

9

Ms. Holmes.

Yes.

10

Mr. Robinson.

I do not believe I talked about this trip on the video.

11

Q

A

Okay.

Correct.

Q

Okay.

I just recall being on one trip call.

I would have been on one call

And then once you get the memos, you said they go toward the

briefing book for the Administrator?

19

A

Correct.

20

Q

Okay.

22

And you can't recall -- other than you were probably on a call about

to assign the memos.

17

21

I could be

it, you can't recall any of the substance of that call or discussions around this trip?

15

18

Exhibit 2.

BY MS. HOLMES:

13

16

Do you remember talking about this trip on the video?

mistaken.

12

14

Okay.

Let's talk about that for a quick second.

Let me find that particular

one.
So the books that you did, you did those daily for the Administrator?

23

briefing books?

24

A

Correct.

25

Q

Okay.

What was included in those?

The

I think you said memos and schedule.


64

1

A

Yes.

The schedule for the day would have been broken down for her.

2

Then there would have been event memos or briefing memos for the corresponding

3

event if they required one or if they needed one.

4

sheets and data for the Administrator just for reference.

5

Q

6

matter experts?

7

A

8

And then the final pages are fact

And the memos, fact sheets, those things come most often from the subject

The memos most often come from the subject matter experts.

The fact

sheets that are at the end of the book, I compile -- or compiled.

9

Q

Okay.

10

A

All the information was pulled from publicly available resources or a daily

11

Where did you pull information from for those?

email that updates the number of loan activity.

12

Q

Okay.

13

A

No.

14

Q

Okay.

15

A

In general, one of the documents contains updated unemployment

So the sheets and fact sheets and data, was that all SBA specific?

What other sort of information was included in those?

16

numbers, numbers of new small business applications when those numbers are updated,

17

information on loan interest rates if those are adjusted, things of that nature.

18

document, in general, is four pages, so --

19

Q

Okay.

20

A

-- there's a lot of stuff in it.

21

Q

I can imagine.

22

Did it ever include information about small business closures?

23

A

24
25

The

I do recall there are times where I highlighted an article about the number of

small business closures and what caused those.
Q

Okay.

When you got the memos back, did you ever review them for


65

1
2

accuracy before giving them to the Administrator?
A

For some memos and some program offices that submitted them, I would

3

review not for policy accuracy but for formatting and to make sure that they were

4

following all procedures that they're supposed to follow.

5

Q

You were kind of like the last check before the Administrator saw it?

6

A

Yes.

7

Q

Okay.

8
9

How did you decide what to give in the fact sheets and data?

Just

what was relevant at the time?
A

Those sheets existed when I came into the role.

I adjusted some numbers,

10

and then other information was requested -- would be requested by the Administrator to

11

include.

12

Q

13

inclusion?

14

A

15

Mr. Sempertegui.

16

I just want to confirm to the extent -- you know, the executive branch has some

17

confidentiality interests in some of the conversations that the Administrator may have

18

had with Tyler, so I want to lay that out.

19

answering this question, but I just want to flag that for you.

20

some information he's providing may be something where we have some interest in.

21
22

Okay.

Do you remember which ones were for specific requests for

I do remember that she requested a breakdown on --

Ms. Holmes.

Real quick, Lauren.

Okay.

I think, you know, we're comfortable with him
And to the extent that

If you want to assert a privilege, obviously, happy to hear

you out.

23

BY MS. HOLMES:

24

Q

Until then, if you could go ahead and answer the question.

25

A

Yes.

The one that I actually do remember the Administrator requesting


66

1

was an updated breakdown of small business ownership by demographics and what each

2

group -- the number of small businesses and what those small businesses -- their

3

percentage that they contribute to the economy.

4

Q

Do you remember how she made that request to you?

5

A

As far as I remember, she made the request verbally.

6

Q

Okay.

7

A

It would have been -- I believe it was sometime last year.

8

were outdated.

9

Q

10

that you can recall?

11

A

12

And was that pretty early on when you took over this role?
The numbers

Were there any particular States or territories that she wanted data from

So -- yes.

For any trip to any State, she, as part of her briefing book,

included data relevant to that State.

13

Ms. Grooms.

Just to clarify, I think you said "she" a couple times.

14

Mr. Robinson.

The Administrator.

15

Ms. Grooms.

Yeah.

16

data in the briefing book?

17

Mr. Robinson.

18

Sorry.

The briefing book included the data, or she included the

The briefing book included the data.

BY MS. HOLMES:

19

Q

At her request for each State?

20

A

Yes.

21

Q

Okay.

And that was a verbal request or written request?

22

A

Sorry.

The request for the data for each State she visited was not a

23

request.

24

places she was visiting.

25

Q

That was just something we've always included to give her background on the

Okay.


67

1

Ms. Meers.

2

Tyler, can you clarify that again just to make sure I'm following?

3

Mr. Robinson.

Can we take a pause?

Yes.

The Administrator requested -- the data the Administrator

4

requested verbally to me was the breakdown of the demographics and what they

5

contributed.

6

That is general information that we provide to the Administrator for background on her

7

visits.

8

The data on each State that she was going to visit was not requested.

BY MS. HOLMES:

9

Q

Okay.

For the breakdown for small business ownership by demographics,

10

did she have particular areas that she wanted to focus on or highlight?

11

geographical areas?

12

A

I do not recall.

13

Q

Okay.

14

[Discussion off the record.]

15

Mr. Robinson.

Yeah.

Particular

Just to clarify, that document was already in the briefing

16

book.

17

believe, was from fiscal year 2020, and she wanted the latest available numbers.

I just updated those numbers.

They were from -- I think the latest number, I

18

Ms. Holmes.

Okay.

19

Ms. Grooms.

Just to clarify, it sounds like the Administrator's specific request to

20

you was for you to update an outdated document that was inside the briefing book.

21

That's the thing you were --

22

Mr. Robinson.

23

Correct.

BY MS. HOLMES:

24

Q

How often did you update that document?

25

A

One document was updated weekly.


68

1

Q

Which one?

2

A

I call it the economic dashboard.

3

Q

Okay.

4

A

The other document was not officially titled anything.

5

top-line data.

6

Q

Okay.

7

A

That document was three pages of information, and of that three pages, I

8

updated daily about 10 numbers.

9

Q

Do you remember which 10?

10

A

Yes.

11

I refer to it as the

They all involved the 7(a), 504, and microloan programs.

A daily

update of where those programs stood.

12

Q

So it's 10 data points within those three programs?

13

A

Around 10.

14

Q

Around 10.

15

Other than the breakdown of ownership by demographic, were there any other

16
17
18
19
20
21
22

Okay.

demographic information or statistics provided in the briefing book?
A

Yes.

And, for her trips to each State, part of that -- the district office

background would have a breakdown of small business ownership in those States.
Q

Did it include any information about the representatives of that State, either

at the State or Federal level?
A

Only -- as far as I can recall, only to the extent of if a Member of Congress or

an elected official was visiting with her.

23

Q

Okay.

24

A

Then it would have a brief bio of the person who was on the trip.

25

Q

Okay.

What about if the White House was with her?

In the time that we have been sitting here, have you been able to


69

1

narrow down the timeframe for your trip with the Administrator to Michigan?

2
3

A

I'm sorry.

I cannot.

The only thing about the timing that I can remember

was it was when the Detroit auto fair was going on.

4

Q

In 2023?

5

A

I believe so.

6

Q

Okay.

So, at the event that was near the Detroit auto show/fair, can you

7

tell me what you remember about that trip?

8

for?

9

A

being present on that trip.

11

SBDA partner at the Henry Ford House.

The first event of the day was the fireside chat with our

And then, as far as I remember, the Administrator visited a manufacturing small

13

business that does metal work.

14

like that.

15

remember that one.

16
17

What you were there

I think I mentioned earlier, as I recall, I do not recall any elected officials

10

12

Who was there?

Q

Like, custom-made metal pieces and railings and things

And then I believe there was an additional small business, but I do not

Okay.

Your Georgia trip you mentioned when you were talking with the

minority, do you remember about when that was?

18

A

Yes.

19

Q

February?

20

A

I believe it would have been February or March.

21

Q

To the best of your recollection, what was the purpose of that trip?

22

A

To the best of my memory, the main purpose of that trip was the

23

That trip was earlier this year.
March?

Administrator speaking at a trade conference about government contracting.

24

Q

Okay.

25

A

And then we did an event -- I believe it would have been February because


70

1

we did an event focusing on access to capital for African-American business owners at

2

Clark Atlanta University.

3
4

Q
trip.

To the best of your recollection -- I think you mentioned two parts of that

So there was one at Clark, and then what was the other location?

5

A

It was at a hotel conference center for a trade show.

6

Q

Okay.

7

A

Yes.

8

Q

Okay.

9

And that was in Atlanta?

For the hotel conference center in Atlanta, do you recall any Federal

or State representatives being present?

10

A

I do recall that other Federal officials spoke.

11

Q

Okay.

12

A

But I do not recall which ones nor do I recall when they spoke.

13

believe the conference lasted over 2 or 3 days.

14

Q

Oh, okay.

So a number of officials, probably?

15

A

Correct.

The Administrator just attended for 1 day.

16

Q

Okay.

17

A

As far as I can remember, it was about government contracting.

18

Q

Was it about expanding government contracting?

19

Do you remember?

20

A

21

It was a -- I

What, to the best of your recollection, was her speech focused on?

Providing opportunities?

I do not remember what -- I had left right as she spoke to jump to the next

event, and I did not read her speech prior, so --

22

Q

By "jump to the next event," what event are you talking about?

23

A

The Clark Atlanta one, I believe.

24

Q

Okay.

25

A

Yes.

So doing advance for that?


71

1
2

Q

Okay.

For the Clark Atlanta University one, do you recall if any State- or

Federal-elected officials attended?

3

A

I do not recall.

4

Q

Okay.

5
6
7

I do not believe so.

And, to the best of your recollection, what did the Administrator

speak about at that event?
A

For that event, she talked about access to capital and the challenges that

African-American business owners face.

8

Q

9

access to capital?

10

A

I do not recall her mentioning specific programs.

11

Q

Okay.

12

Ms. Holmes.

13
14
15

Did she highlight any particular programs within the SBA that could expand

Okay.
We're going to introduce majority exhibit 3, which we will hand out

in short order.
For the record, this is a press release published on January 12th, 2024, entitled
"Readout of SBA Administrator Guzman's Visit to Allentown with President Biden."

16

[Robinson Majority Exhibit No. 3

17

was marked for identification.]

18

BY MS. HOLMES:

19

Q

Okay.

Mr. Robinson, do you remember this trip occurring?

20

A

Yes.

I do remember this trip.

21

Administrator.

22

Q

Okay.

23

A

Once again, my role would have just been to prepare the briefing book for

24

this trip.

25

Q

I was not on this trip with the

What was your role in preparing for this trip?

Do you remember anything that was specifically requested for the briefing


72

1
2

book about this trip?
A

I do not remember anything out of the ordinary.


73

1
2

[12:18 p.m.]

3

BY MS. HOLMES:

4

Q

When you say out of the ordinary, meaning?

5

A

Anything that would not have been in the briefing book in general.

6
7

There

was no special request.
Q

Because it was with the President of the United States, were there any

8

additional information, stats, things that the Administrator needed to prepare for an

9

event specifically with the President?

10

A

11

for every event.

12

Q

There's probably additional logistics you had to go through, though, right?

13

A

For this event, I believe so, because there are Secret Service logistics that we

14

have to deal with.

15

Q

16

To the best of my knowledge, no.

Yeah.

We try to prepare her as well as we can

Do you remember who from the SBA went with the Administrator

on this trip?

17

A

I have no knowledge of who went with the Administrator on this trip.

18

Q

Okay.

19
20
21
22
23
24
25

Do you remember if there were any Federal or State-elected officials

on this trip?
A

I do not remember what elected officials were invited or if they were invited

or present.
Q

You mentioned at the beginning of today that you only knew about the

Michigan MOU from the press release.
A

Is that correct?

I remember it being discussed that the press release was going out.

not read the press release.

I did


74

1
2
3

Q

Okay.

To the best of your recollection, when was that conversation prior to

the press release being released?
A

To my best knowledge, it was during a meeting when we were discussing the

4

schedule for the next week.

5

released.

6

Q

So that would put you beginning of April-ish?

7

A

I do not know when the actual press release was released.

8

Q

Okay.

9

So it would have been a week before the press release was

The press release went out on April -- or March 19th.

So -- sorry -- beginning of March-ish, a week before then?

10

A

Yes, it would've been the week before.

11

Q

Prior to that discussion, had you heard anything about a memorandum of

12

understanding or an agreement with the State of Michigan?

13

A

No.

14

Q

Prior to that agree -- prior to that meeting, had you ever worked with

15

anyone at the Michigan secretary of state's office?

16

A

No.

17

Q

After that meeting, did you work with anyone from the Michigan secretary

18

of state's office?

19

A

No.

20

Q

So it's your testimony that you have not had any contact with anyone from

21

the Michigan secretary of state's office?

22

A

As far as I'm aware.

23

Q

Okay.

During a briefing with Jennifer Kim, who we talked about earlier, a

24

committee staffer told that the negotiations with Michigan over the MOU began in

25

December of 2021.

What was your role with the SBA then?


75

1

A

December of 2021, I was -- sorry.

2

Q

Yeah, yeah.

3

A

December of 2021, I was not with the SBA.

4

Q

Can you remind me of where you were at?

5

A

December of 2021, I was unemployed.

6

Q

What were the circumstances that led to that?

7

Ms. Meers.

8

Wait.

This is -- can we take a pause -- outside the scope of this

transcribed interview.

9

Ms. Holmes.

December 2021?

10

Ms. Meers.

His employment status.

11

Ms. Holmes.

It's just -- yeah, it's just background of where he was at and what

12

he was doing at the time he --

13

Ms. Meers.

I think he answered the question, though.

14

Ms. Holmes.

Okay.

15

BY MS. HOLMES:

16

Q

Do you know what Executive Order 14019 is?

17

A

I do not.

18

Q

It's the executive order involving voter registration given by President Biden

19

in 2021.

20

him becoming President and then went over to the SBA shortly thereafter.

21
22

I think you said that you were working on the Biden campaign leading up to

You don't recall any discussions about the executive order asking agencies to
become -- or to help register voters in the election?

23

A

I do not recall anything about the executive order.

24

Q

Do you know anything about the executive order now?

25

A

I -- yes, I do now.


76

1

Q

2

Ms. Grooms.

Outside of counsel conversations.

3

Mr. Robinson.

Yeah, what I know is from counsel conversations.

4

What do you know about the executive order now?

BY MS. HOLMES:

5

Q

An attorney was in the room?

6

A

Yes.

7

Q

Representing you about this deposition --

8

A

Yes.

9

Q

-- transcribed interview?

10

A

Yes.

11

Q

Okay.

12
13
14
15

I will note for the record that we don't always recognize

attorney-client privilege, but I'm not going to push on that one right now.
As part of the discussion that you had about the press release going out, what do
you remember from that discussion?
A

To my best knowledge, it was just that the communications team going over

16

their strategy and event for the upcoming week, and just noting that they were doing the

17

press release about an MOU.

18

Q

Was there anything different about this press release?

19

A

I -- I do not review press releases.

20

Q

Sorry.

21

Was there anything different about the discussion around this press release versus

22

Let me rephrase that.

other press releases?

23

A

Not to my memory, no.

24

Q

Okay.

25

Were you aware that the Administrator was testifying before our

committee the following day?


77

1

Ms. Grooms.

The following day, following what?

2

Ms. Holmes.

From the press release.

3

Ms. Grooms.

So the day after?

4

BY MS. HOLMES:

5

Q

It's March 20th.

So you were going over the schedule, right?

6

that it was going out on the 19th.

7

committee on the 20th?

So you said

Were you also discussing her appearance before this

8

A

Just that she was appearing before the committee that day.

9

Q

Was there any discussion about whether or not this might come up, to the

10

best of your recollection?

11
12

A

No, not -- to the best of my knowledge, it was not.

run-through of her weekly schedule.

13

Q

Okay.

15

A

Correct.

16

Q

Okay.

14

It was just a

After the press release was made public, you said you didn't read it,

right?

Do you have any knowledge about what the memorandum of

17

understanding does or what it was going to do for Michigan or how it would impact your

18

events or your job?

19

Ms. Grooms.

Outside of conversations with counsel in preparation for this.

20

Mr. Robinson.

Yeah.

Outside of conversation with the counsel, I did not

21

under- -- I had no knowledge of the MOU or what it contained or any information other

22

than there was an MOU signed.

23
24
25

Ms. Holmes.

Okay.

Do you know who at the SBA is in charge of implementing

this MOU?
Mr. Robinson.

I do not.


78

1

Ms. Holmes.

2

this MOU or outside of it?

3

Ms. Grooms.

Do you mean training from the SBA --

4

Ms. Holmes.

Yes.

5

Ms. Grooms.

-- voter registration?

6

Mr. Robinson.

No, I have not received training from the SBA on voter

7

registration.

8
9
10

Have you received any training under -- for voter registration under

BY MS. HOLMES:
Q

And you haven't talked to anyone from the Michigan Department of State,

so no training from them either?

11

A

Correct, no training from them.

12

Q

Okay.

13

maybe 6 months ago?

14

A

15

few months ago.

16

Q

17

You said you got Hatch Act training, right, and the most recent was

I believe -- yes, I have received Hatch Act training, and the most recent was a

Okay.

Was there anything in that training about voter registration

occurring at SBA events?

18

A

Not that I can recall.

19

Q

Okay.

20

To the best of your knowledge, does the SBA have the voter

registration link up on the website?

21

A

I do not know.

22

Q

You said you recently moved over to the disaster loan -- can you remind me

23

what it's called?

24

A

The Office of Disaster Recovery and Resil- -- or Recovery and Resilience.

25

Q

Okay.

Sorry.

And in your day-to-day roles there, do you have any overlap


79

1

between disaster loans and voter registration?

2

A

No, I do not.

3

Q

Okay.

4

A

Yes, I have.

5

Q

What do you know about them?

6

A

I know that they are an organization that focuses on registering -- I believe

7

Have you ever heard of an organization called Rock the Vote?

their target is youth voters.

8

Q

And what context did you hear about them or do you know about them?

9

A

Just in the context of having been involved in political campaigns for a

10

number of years.

11

Q

12

of your knowledge?

I've never personally worked with them.

Okay.

Do you know if anyone at the SBA has worked with them, to the best

13

A

To my best of my knowledge, I do not know.

14

Q

Okay.

15

A

No.

16

Q

Okay.

17

A

I have general awareness of what we refer to as the small business boom.

18

Q

And what did you refer to as the small business boom?

19

A

From what I understand, it is the growth of small businesses since the end of

20

the pandemic.

21

Q

22

And you personally have not worked with them?

Do you recall what the small business boom is?

Did that include any information about the decline of other small businesses

since the pandemic or is it just the ones that are being started?

23

A

As far as I can remember, it is the businesses being started.

24

Q

Is that -- is that an SBA --

25

Ms. Harrington.

Is this within the scope, Lauren?


80

1

Ms. Holmes.

2

Mr. Sempertegui.

3

Ms. Holmes.

You can't make that objection, Ellen.
Yeah.

Lauren, is this within the scope?

Yes, this is related to an event that I would like to discuss, which we

4

can actually introduce right now.

5

Administrator has been traveling and promoting the small business boom.

This is going to be majority exhibit 4.

6

[Robinson Majority Exhibit No. 4

7

was marked for identification.]

8
9
10
11

Ms. Holmes.

Okay.

Because the

So this is the White House report on the Biden-Harris small

business boom, which was talked about in the -- what was marked as majority exhibit 2.
So you mentioned that, as you understand, that the SBA understood the small
business boom to be a calculation of new businesses started since the pandemic?

12

Ms. Beca-Barragan.

13

Ms. Holmes.

14

Ms. Beca-Barragan.

15

Ms. Holmes.

16

Ms. Beca-Barragan.

17

Ms. Grooms.

This is exhibit 4?

18

Ms. Holmes.

Yeah.

19

Ms. Grooms.

And just for the record, he has not seen this document before.

20

I'm sorry.

Is this exhibit 2 or 4?

This is 4, but it's discussed in the press release of exhibit 2 -Okay.

-- which is the scoping answer.
Thank you.

Sorry.

I should've crossed that out.

BY MS. HOLMES:

21

Q

You've not seen this document before?

22

A

No.

23

Q

Okay.

24
25

That's okay.

We won't do the line by line through that then.

Yeah, nobody needs that stress.
Okay.

But you said that the SBA understood it to be how many small businesses


81

1

that have been started since the start of the pandemic?

2

A

That is how I understand it.

3

Q

Okay.

4

In what context did you use this sort of terminology or phrasing?

Was it in the briefing books for the Administrator?

5

A

I don't believe I've ever used it in an individual context, other than --

6

Q

Okay.

7

A

-- it would've been in the Administrator's talking points or in her briefing

9

Q

Okay.

10

A

Occasionally.

11

Q

Occasionally.

12

Who drafted those?

13

A

14

Public Liaison --

15

Q

Okay.

16

A

-- or Public -- what are they called?

8

17

book.
So talking points within the briefing book too?

Okay.

Overall talking points are drafted by the Office of Communications and

Sorry.

OCPL, Office of

Communications and Public Liaison.

18

Q

That's okay.

19

A

I'm sorry.

20

Q

I just work here.

21

Ms. Grooms.

That's why we say, "to the best of my recollection."

22

Ms. Holmes.

Covers all things.

23
24
25

I didn't mean to do that to you.
Okay.

BY MS. HOLMES:
Q

Okay.

So the "small business boom" terminology was just something you

heard around the office?


82

1

A

Yes.

2

Q

Okay.

3

A

As far as I can recall, it is just a common phrase that we use -- that the

4

Do you remember who you first heard it from?

Administrator uses in events to describe the growth of small businesses.

5

Q

Okay.

6

A

I can't recall a single person who -- anytime they specifically mentioned it.

7

Q

Okay.

8

now and then?

9

A

Correct.

10

Q

Okay.

11

A

Yes.

12

Q

Do you know if there is a ongoing investigation of the SBA and/or you by the

But it was just kind of a general term used around the office every

Do you know what the Office of Special Counsel is?

13

Office of Special Counsel?

14

Mr. Cantlon.

I'm going to object to that question.

15

Ms. Holmes.

On what grounds?

16

Mr. Cantlon.

The OSC process is confidential in nature, so he can neither deny or

17

admit there is an investigation, so I'm going to let that be.

18

Ms. Holmes.

I think the rights of Congress to obtain information override that.

19

Mr. Cantlon.

Well, the actual OSC itself is a confidential process, so we want to --

20

Ms. Holmes.

Sure.

21

Mr. Cantlon.

-- respect them.

22

Mr. Sempertegui.

23

questioning towards -- at the end?

24

questions that you had, so we can --

25

Ms. Holmes.

We want you to respect that as well.

So, Lauren, may I suggest, can we come back to this line of

Okay.

And then we get over -- we can cover the other


83

1

Mr. Sempertegui.

2

Ms. Holmes.

3

Mr. Sempertegui.

4

Ms. Holmes.

5

Mr. Sempertegui.

6

Ms. Holmes.

7

Mr. Sempertegui.

8
9

I think we're going to have a little back-and-forth on this one.

Okay.
So we save the best for last, if you will.

Okay.
Are you okay with that?

Yes, we can do that.
Okay.

Thank you so much.

BY MS. HOLMES:
Q

All right.

The last part I want to go through on the video is not necessarily

10

specific quotations that happened or did not happen or things you confirmed or denied,

11

but I think throughout the video, it is portrayed that you are arguing that the SBA has

12

been going to battleground States to campaign on behalf of President Biden, only inviting

13

Democrats, not Republicans, et cetera.

14

You have denied all of those statements on the record.

15

The Small Business Committee did their own research, and we looked at all of the

16

SBA press releases from the time in question that you had been discussing at the video,

17

and we found 27 trips to battleground States just from the public press releases alone.

18

Fourteen of them included a Democrat Member of Congress, and only one included a

19

Republican Member.

20
21
22
23
24
25

So from objective third-party research of -- or, I guess not objective, but subjective
SBA press releases, it does seem that your statements had some validity to them.
Can you help me reconcile your statements then with your statements now with
what is publicly available about the trips that the Administrator has taken?
A

Once again, during the video I did say those things.

The status of a State as

a battleground State has never, in my experience, been discussed as a reason to go to a


84

1
2

certain State.
As far as coincidence between how many visits the Administrator made to those

3

States, I can't say.

4

Yeah.

That's, as you said, you know, something that was subjective for you.

You know, in my experience and my work at the SBA, the status of those

5

States being battleground States or important to an election have never been the reason

6

we went to those States.

7
8
9
10
11
12
13

Q

To the best of your recollection or knowledge, were there ever events that

you guys did that press releases did not go out on?
A

I do not know what events press releases go out on.

I'm not part of the

press release process.
Q

Okay.

So you've denied everything you said in the video.

How do we

know that you're telling us the truth today?
A

The video, once again, was in context of, I was on a date.

I was not -- one, I

14

was not thinking about trying to be factually accurate.

15

were made to impress somebody.

16

fears that -- she was visibly concerned about the President losing reelection.

You know, those statements

Some of those statements were made to alleve her

17

I think, you know, on a date you're not trying -- you're not under the same

18

circumstances that I am right now, being in a House committee situation and, you know,

19

having to, by law, tell the truth.

20

regret everything I said in the video.

21

the truth of my experience at the SBA.

22
23
24
25

You know, I said those things on the video.
I wish I never would've said it.

I deeply

It does not reflect

You know, what I've said today is the truth, as I know it and as I understand it,
and -- yeah.
Q

Okay.

And you mentioned that you moved from your position in the

Administrator's office to the disaster office.

And it was your testimony that it was done


85

1

voluntarily, and you were not asked to move there but you wanted to move there.

2

Ms. Grooms.

So I think he said he's on a detail.

3

Mr. Robinson.

Yes.

4

BY MS. HOLMES:

5

Q

A detail?

6

A

I am on a detail.

It was -- I did ask for that opportunity.

As I understand

7

it, part of it was also to relieve the stress on me.

8

in the position I was in, Arthur expressed concern about my mental well-being and ability

9

to do the job.

10

Q

So Arthur was the one that had that conversation with you?

11

A

Yes.

12

Q

Okay.

13

A

The beginning of May.

14

Q

Beginning of May.

15

But you don't believe that was in retaliation for this video?

16

A

I do not believe it was in retaliation.

17

Q

Okay.

18

After the video coming out and being

And you officially made the switch at the end of May?

Excuse me.

Sorry.

Did you discuss this interview with any of the Democrat members or

Democrat staff on this committee prior to today?

19

A

No, I did not.

20

Q

To the best of your knowledge, did anyone at the SBA discuss this interview

21

with the Democrats prior to today?

22

A

I have no knowledge of anyone's conversations outside my own.

23

Q

Okay.

24
25

And are you aware of the SBA contacting any other secretaries of

state to discuss voting registration in those States?
A

I am not aware.


86

1
2

Q

Are you aware of the SBA contacting other secretaries of states to discuss

small business concerns?

3

A

I do not know if those -- if they contact the secretary of states, no.

4

Q

Okay.

5

of states?

6

A

7

I can remember.

8

Q

9

Ms. Grooms.

As part of your job?

10

Mr. Robinson.

As part of my job, yeah.

11

Ms. Grooms.

With the SBA?

12

Mr. Robinson.

Yes.

13

Ms. Holmes.

Thank you for the clarification.

14

I think we can jump back to the OSC, so --

15

Mr. Sempertegui.

So in your experience, you never had contact with other secretaries

I have -- personally have never had contact with secretaries of state, as far as

Okay.

Well, I think, look, as it relates to any questions related to

16

OSC, right, the investigation process, to the extent there's any activity going on related to

17

investigation, whether, you know, individuals are subjects or whether they're witnesses

18

to the investigation, all of that is confidential, right?

19

it's confidential.

20

Tyler to sort of discuss any topics related to OSC.

21

And OSC sort of makes it clear that

And so we are in a position where we don't think it's appropriate for

Certainly to the extent that you have some specific questions, we're happy

22

to -- you send those over to the agency -- we're happy to look them over and do our

23

necessary, you know, research to confirm what we're providing you is not in any way sort

24

of putting the SBA in a position where we may not be following statutory or regulatory

25

guidance, right?

That's the big concern.


87

1
2

Ms. Holmes.

So you're telling me that the OSC is exerting privilege over that

information?

3

Mr. Sempertegui.

4

Ms. Holmes.

5

Mr. Sempertegui.

No.

Are you exerting privilege over that information?
I'm telling you that information as related -- any information

6

related to OSC investigation, right, enforcement action, if it does exist or it doesn't exist,

7

all of that is confidential in nature.

8
9
10
11

Ms. Holmes.

But the committee has a right to get that information and that

confidential information, and you can't assert confidentiality privilege on behalf of OSC.
Mr. Cantlon.

But we're required to keep confidentiality under that process, so

we can't disclose that information.

12

Ms. Holmes.

13

we'll just set it up.

Okay.

We can have a conversation offline with OSC and you, and

14

Mr. Sempertegui.

15

Ms. Holmes.

16

Mr. Sempertegui.

17

Ms. Holmes.

Are we good?

18

Mr. Eckhardt.

Yeah.

19

Ms. Holmes.

Okay.

20

[Recess.]

Yeah, of course.

Okay.

Sounds good.

Yeah, that makes sense.

We can go off the record.


88

1
2
3
4

[1:38 p.m.]
Ms. Harrington.

7
8
9
10
11
12

Thank you, Tyler.

We appreciate you being here.

Once again, it's Ellen Harrington and Renata with the minority.

5
6

Okay.

BY MS. HARRINGTON:
Q

Is there anything you would like to add at the beginning, or would

you -- anything you'd like to add to this?
A

Yes.

Ms. Holmes had asked earlier if there is anything I'd like to clarify,

misstatements from the video.

I have a few.

This is not a comprehensive list.

And want to also thank you for, like, not wanting to -- save the embarrassment of
having to watch the video.
In my experience, the White House -- the White House, nor anyone at the SBA,

13

has declared or said that we should only invite Democrats to SBA events.

14

White House has never said, don't invite Republicans to SBA events, and any impression

15

that I gave that -- or any statement I gave that gives that impression, I'm sorry for.

16

Two, I've never heard Administrator Guzman say that the SBA is going to a

The

17

battleground State to campaign for President Biden.

18

not seen the Administrator, or anyone else at the SBA, use official times or resources to

19

campaign for President Joe Biden or anyone else.

In fact, in my work at the SBA, I've

20

With regard to the Montana trip that is discussed on the video -- and, again,

21

acknowledging that I don't know the exact context of the video -- I did not hear anyone at

22

the SBA, including the Administrator, say, we're going to Montana to help Senator Tester

23

or discuss the need for him to win the seat in Montana to maintain a Senate majority.

24

also did not hear anyone at the White House and, to the best of my knowledge, no one at

25

the White House has said, for the SBA to invite Senator Tester but not invite the other

I


89

1

Senator or the two Members of Congress because they're Republicans.

2

impression of that is not accurate.

3

Any contrary

And on the video, Grace said and talked about indirectly campaigning for

4

President Joe Biden.

5

words and not mine.

I don't know what she meant by that phrase.

Those were her

6

And, again, in my work at the SBA, I've not seen the Administrator, or anyone else

7

at the SBA, use official time or resources to campaign for President Joe Biden or anyone

8

else.

9

And there's also a reference in the video to the Administrator testifying before

10

Congress.

11

the Administrator for her appearing before Congress.

12

contrary statements or impressions from the video that imply that are not accurate.

13

I want to make it clear that I was not involved in any of the preparation for
That's not part of my job, and any

And I just hope that clarifies kind of the scope of everything and any concerns you

14

all might have.

15

Q

16

I just want to go through some events.

Okay.

Thank you, Tyler.

We appreciate that.
I just did a little bit of research on my

17

own and quickly found some events in which the Administrator traveled -- traveled with

18

Republican Members of Congress.

19

Committee.

20
21
22
23

I limited my research to the Small Business

So you may or may not be aware of these events, but I just want to ask you
quickly.
Here is the first press release we'll enter into the record as exhibit A, and if you
pass it along so everyone can have a copy.

24

[Robinson Minority Exhibit No. A

25

was marked for identification.]


90

1

Ms. Harrington.

2

Ms. Grooms.

3

Ms. Harrington.

4

Ms. Grooms.

5

Ms. Harrington.

6

And you may or may not be aware of these events, but I'm just wondering if you

7

were aware that the Administrator traveled to Fort Hood in Texas to highlight the Boots

8

to Business Program with Chairman Williams of the House Small Business Committee in

9

March 2023?

Were you aware that the Administrator traveled --

Can you pause for 1 second.
Thank you.

Do you have stickers?

I'm sorry.

You're fine.
Great.

Thank you.

10

Mr. Robinson.

Yes, I remember that trip.

11

Ms. Harrington.

You do remember that trip.

12

Let me pass, this will be exhibit B.

Thank you.

13

[Robinson Minority Exhibit No. B

14

was marked for identification.]

15

Ms. Harrington.

Were you aware the Administrator did an event with

16

Ms. Van Duyne in February 2022 to highlight the Shuttered Venues Operating Grant

17

Program?

18

Mr. Robinson.

I do not recall this event.

19

Ms. Harrington.

Okay.

Thank you.

20

[Robinson Minority Exhibit No. C

21

was marked for identification.]

22

Ms. Harrington.

23

Were you aware the Administrator met with Ms. Salazar of the Small Business

Here's exhibit C.

24

Committee to highlight government contracting opportunities and visited small

25

businesses in Miami in March 2022?


91

1

Mr. Robinson.

2

Congress were on that trip.

3

Ms. Harrington.

4

And the last one I have -- and, again, this is just super quick, cursory research.

5

I remember a trip to Miami.

Okay.

There could very well be more.

I do not recall which Members of

Thank you very much.

This is exhibit D.

I appreciate that.


92

1

[Robinson Minority Exhibit No. D

2

was marked for identification.]

3
4

BY MS. HARRINGTON:
Q

Were you aware the Administrator conducted a Main Street walking tour

5

with Mr. Aaron Bean of Florida in August 2023, also a member of the House Small

6

Business Committee?

7

A

Yes, I was aware of this trip.

8

Q

Okay.

9

So to the best of your understanding, can you tell me why the Administrator

10

travels?

11

A

Thank you.

As I said earlier, the Administrator travels throughout the country strictly to

12

highlight the opportunities that the SBA provides for small business owners and to

13

highlight the successes of our small business owners but also to learn about the

14

challenges they face in operating their businesses.

15

Q

And I just do want to reiterate for the record that these are all trips with

16

Republican Members of Congress on our committee.

17

It was a quick -- it was a quick search.

18

Okay.

And, again, there could be more.

So let's turn to -- and I think we've clarified this, but I just want to go

19

through it quickly just to clear everything up.

20

the Hatch Act.

21

Hatch Act?

The majority has asked questions about

Do you have any reason to believe that the administration violated the

22

A

No, I do not.

23

Q

Okay.

24

The majority also talked a little bit about the MOU.

And actually they brought

25

you in today to talk about voter registration and that MOU.

And I just want to be clear

Thank you.


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1

for the record, do you have any understanding -- in your role, do you have any

2

understanding of the MOU and the MOA?

3

A

No, I do not.

4

Q

And there was no involvement with your role in the MOU or MOA?

5

A

Not that I recall.

6

Q

Okay.

7

And I do want to just clarify, you mentioned some of your responsibilities on the

8

Thank you.

trips with the Administrator were limited to advance work, correct?

9

A

Correct.

10

Q

Correct.

11

You were also asked a series of questions about different events in which

Okay.

Thank you.

12

Members were or were not present.

13

session on those days?

Do you know whether or not Congress was in

14

A

I do not know.

15

Q

Okay.

16

In the first hour of the deposition (sic), you stated that you received emails from

17

the White House asking -- or the White House mentioning, or an invitation to attend an

18

event.

Thank you.

Is your understanding that this was an invitation or a command?

19

A

It is my understanding that they were all invitations.

20

Q

Okay.

21

Ms. Grooms.

22

[Discussion off the record.]

23

Mr. Robinson.

24
25

Perfect.

Thank you.

Could we just have a minute?

And to clarify, I did not receive the emails personally.

They

were submitted to the scheduling inbox.
Ms. Harrington.

Okay.

Thank you.

My apologies for that.

Thank you.


94

1
2
3

Let's see.

I appreciate you being here today.

question.
I read through the May 7th, 2024 letter to you from Chairman Williams that

4

accompanied the subpoena.

5

going to read it.

6

There's a line in there that caught my attention, and I'm

In this video, you made allegations about improper conduct at SBA related to this

7

investigation.

8

wrong because I think you said this.

9

make any allegations of misconduct at SBA, correct?

10
11

I do want to ask another

I just want to make sure I hear your perspective.

Mr. Robinson.

And correct me if I'm

You thought you were on a date, and you did not

Yes, I was thought -- I never made any allegations of misconduct

on any SBA official.

12

Ms. Harrington.

13

So, again, I really appreciate you being here today.

Thank you very much.
I want to wrap this up just

14

generally.

15

interfering with elections, is that an accurate allegation, based on your knowledge?

If we leave here today and Republicans make claim that the administration is

16

Mr. Robinson.

Based on my knowledge, no.

17

Ms. Harrington.

Okay.

18

Do you have anything you want to add?

19

Ms. Beca-Barragan.

20

Ms. Harrington.

21

We're good.

22

Ms. Holmes.

23

Thank you very much.

No.

Okay.

Tyler, thank you very much.

We just have a few questions to -- just give us a minute, and then

we'll be done.

24

Off the record.

25

[Discussion off the record.]


95

1

Ms. Holmes.

2

I just want to respond to a couple of the points brought up by the minority and

3

We can go back on the record.

the exhibits they introduced.

4

As we all saw, there were four events total introduced.

One was in one of the

5

battleground States that we had talked about earlier, which is Florida, which was included

6

in our original calculation of all of the press releases done by SBA that are publicly

7

available.

8
9

Within the battleground States, as I said before, 27 trips to battleground States, 14
of them included a Democrat Member, and only 1 included a Republican.

10

If you add back in all the other States, as the minority did, the total is still quite

11

stark.

12

members, only 2 of the party.

13

The Democrat numbers were invited to 26 out of 73 total events, and Republican

Moving into your list of things that you believe -- or are asserting today that were

14

misstatements done during the video.

15

any allegations in the video.

16

what "allegations" means, so I'm just going to clarify what I mean when I say

17

"allegations."

18
19

Ms. Grooms.

The minority said that you didn't actually make

I think we have a fundamental misunderstanding about

If we could, I just think we might just be using the word

"allegation" differently.

20

Ms. Holmes.

Yeah.

21

Ms. Grooms.

So if maybe we could just use a word other than "allegation," that

22
23

That's what I was saying, yeah.

would make it a little more clear.
Ms. Holmes.

Yes, okay.

So I will define what I meant by "allegations" by using

24

other words, which would be that you made statements in a video about misconduct at

25

the SBA which you are now denying in person today, which I recognize and I understand,


96

1

but the statements were, in fact, made and they were made by you.

2

Ms. Sawyer.

So can I just ask a clarifying question?

3

Ms. Holmes.

Absolutely.

4

Ms. Sawyer.

I mean, I think we would all agree that he made statements about

5

conduct that he has tried to explain or said were misstatements, but I don't know that we

6

would all agree that every statement was about misconduct.

7

Ms. Holmes.

That's fine.

8

Ms. Sawyer.

-- if we could just have that clarified.

9

Ms. Holmes.

Yeah, back on the record.

10

Ms. Beca-Barragan.

So --

Totally fine.

Okay.

And for the record, the definition of "allegation," according

11

to the dictionary, is a claim or assertion that someone has done something illegal or

12

wrong, typically one made without proof.

13

Ms. Holmes.

Yes, which is how I was using the term, he made allegations

14

without any backing to them, and that's what we were investigating, was the statements

15

made without any evidence behind them, right?

16

BY MS. HOLMES:

17
18

Q

Okay.

So now that we're done with our grammar lesson, I just have a couple of,

like, final questions for you.

19

You stated on the record earlier that, as far as you were aware, there were no

20

mixed trips, meaning official and political travel, occurring within your knowledge base

21

during your tenure at the SBA?

22

A

As far as I'm aware.

23

Q

Okay.

24

How is it separated?

25

I just wanted to make sure.
If there were to be a political event, would that be

something just an entire -- like, does the campaign handle that?

Is it completely


97

1
2
3

siphoned off from your scheduling?
A

Yes.

Anything that might be considered, I guess what you call, mixed

travel, is completely separated from my role.

4

Q

5

Ms. Grooms.

6

[Discussion off the record.]

7

Mr. Robinson.

8

Okay.

Thank you for that clarification.
Can we just --

Yeah.

And with the political stuff, because I had -- it was not

part of my role, I don't know anything about it.

9

Ms. Holmes.

Okay.

10

Mr. Robinson.

Yeah, I have no insight to it.

11
12

BY MS. HOLMES:
Q

Okay.

We talked about earlier the small business boom, and you said you

13

just kind of heard people saying it around the office.

14

around the office that -- talking about battleground States?

Did you ever hear people saying

15

A

No, I did not.

16

Q

Did you ever hear anybody talking around the office about campaigning for

17

President Biden?

18

A

No, I have not.

19

Q

Did you ever hear anyone around the office talking about campaigning for

20

Democrat Members of Congress?

21

A

To the best of my recollection, no.

22

Q

For the trips, as far as you know, are there any transcripts or readouts from

23

every trip that the Administrator goes on?

24

A

Not that I'm aware of.

25

Q

Okay.

Do you see her speeches beforehand, are they part of the briefing


98

1

book?

2

A

I am emailed a copy.

3

Q

Okay.

4

A

I generally do not -- I generally do not read them.

5

Q

That's okay.

6

A

I just put them in the book.

7

Q

That's okay.

8
9
10
11
12
13
14
15
16
17

So you're emailed a copy, you add it to the book, and then

hand it to the Administrator?
A

Generally, yes.

There are times when she prints it out on her own and just

takes it on her own.
Q

Okay.

You also mentioned at the beginning of today that you were the

interim director of scheduling or something to that effect?
A

Yes.

There wasn't an official title, but I served as the only person in the

office managing the scheduling inbox.
Q

Okay.

So that means you saw all the requests that come in, and then what

did you do with those requests?
A

That is part of the scheduling process where I would make a list of all the

18

requests and get all the details necessary to discuss the invitation with the group I had

19

mentioned earlier that saw the Administrator's events --

20

Q

Okay.

21

A

-- and gives a recommendation.

22

Q

And in my final hour, we talked about the -- whether or not there was the

23

existence of an OSC investigation.

24

to ask you, do you know the answer to that question, of whether or not there is an

25

investigation?

I'm not going to ask you that question, but I am going


99

1

Ms. Meers.

2

Mr. Robinson, I'm instructing you not to answer that question.

3

Mr. Robinson.

4

Mr. Sempertegui.

5

I want to take a pause as agency counsel.

Okay.
And for the record, Lauren, as we discussed previously, we will

work with the committee to sort of address that specific question.

6

Ms. Holmes.

7

Mr. Robinson, I'm not sure you're aware, but Title 5, Section 7211 of the U.S. Code

Okay.

8

states the right of employees, individually or collectively, to petition Congress or a

9

Member of Congress, or to furnish information to either the House of Congress or to a

10

committee or a member thereof, may not be interfered with or denied.

11

Do you understand?

12

Ms. Grooms.

I'm not sure I understand.

13

Ms. Holmes.

It's the right of an employee to petition Congress -- to furnish

14

information to Congress.

15

Ms. Grooms.

Okay.

16

Mr. Robinson.

Yes.

17
18

What -- what --

BY MS. HOLMES:
Q

Okay.

Title 5, Section 2302 of the U.S. Code states that the department

19

and/or agency, cannot take or threaten to take personal action against you, including a

20

charge of your benefits -- a change to your benefits -- sorry -- for any disclosure to

21

Congress, including to any committee of Congress.

22

Do you understand?

23

A

Yes.

24

Q

Are you aware that the representatives of the agency do not represent your

25

interests but instead those of the government?


100

1

A

Yes.

2

Q

Are you aware that it's possible your personal interests may diverge from

3

those of the government?

4

A

Yes.

5

Q

Are you aware that the discretion whether to answer questions, even if

6

instructed not to, resides solely with you?

7

A

Yes.

8

Q

And are you aware that if you refuse to answer any questions today, either

9

as instructed or otherwise, the committee has authority to compel your testimony?

10

A

Yes.

11

Q

Okay.

12

So I'm just going to ask one more time.

Do you know the answer of

whether or not there is an OSC investigation?

13

Ms. Grooms.

Can we pause on this?

14

Ms. Holmes.

Yeah.

15

Ms. Grooms.

It does seem like -- let's stay on the record.

We can go off the record.
It seems like what I

16

had thought that the agreement was that you were going to work this out with OSC.

17

Clearly, OSC knows whether OSC is conducting an investigation, and that would be the

18

most appropriate place to ask this question to.

19

It does seem as if we're putting Tyler into the middle of a debate that's not really

20

involving Tyler.

21

and going above and beyond and giving you information, after being instructed by

22

counsel for the agency not to do so.

23

uncomfortable situation where I think our preference would be for you to work this out

24

with agency counsel and with OSC, who obviously can decide whether the -- whatever

25

OSC is or is not doing is something that OSC feels is appropriate to share with you or not

And you just said a number of things about him sort of disagreeing with

And I think the -- that puts him in a particularly


101

1

share with you, as opposed to going about it through Tyler.

2
3

So we would ask that you withdraw the question and proceed in the alternative
process instead of, you know, pressuring Tyler to answer it at this point.

4
5

We have not had the opportunity, as personal counsel, to consult with OSC about
whether OSC has concerns about Tyler answering this question, if that makes sense.

6

Ms. Holmes.

That's fine.

Your preference is noted.

I'm not going to withdraw

7

the question.

I'm not asking what the answer to whether or not there is an

8

investigation.

I'm just asking if he knows that information.

9

ask the followup.

10

Ms. Harrington.

11

Ms. Holmes.

12

Ms. Harrington.

13

Ms. Holmes.

14

scope of the agreement.

15

That's it.

I'm not going to

This is beyond the scope again.

No, it's not.
This is beyond the scope --

Ellen, you can't make that assertion, and, no, it's not beyond the

So you can instruct your client not to answer, and that's fine, and then we can talk

16

offline, but I'm not going to withdraw the question of whether or not he knows the

17

answer to the question.

18
19

That's all -- I'm not going to ask the followup.
one.

All I want to know is if he knows the answer.

20

Ms. Grooms.

Can we take a pause?

21

Ms. Holmes.

Yes.

22

[Discussion off the record.]

23

Ms. Holmes.

24

Okay.

25

I will give you my word on that

We can go off the record.

On the record.

So I'm going to ask again.

Do you know the answer to the question of

whether or not there is an active and ongoing OSC investigation at the SBA?


102

1

Mr. Robinson.

I know the answer.

2

Ms. Holmes.

Okay.

3

We can go off the record.

4

[Discussion off the record.]

Thank you.


103

1
2

[2:06 p.m.]

3

Ms. Holmes.

4

The committee recognizes and appreciates that you were here voluntarily today,

Okay.

We're back on the record.

5

Mr. Robinson, and of course all the attorneys in the room, we appreciate your

6

cooperation and thank you for being here.

7

Ms. Grooms.

Thank you.

8

Ms. Holmes.

Okay.

9

[Whereupon, at 2:06 p.m., the interview was adjourned.]

We're done.

Off the record.


104

1

Certificate of Deponent/Interviewee

2
3
4
5

I have read the foregoing ____ pages, which contain the correct transcript of the
answers made by me to the questions therein recorded.

6
7
8
9
10

_____________________________
Witness Name

11
12
13
14
15

_____________________________
Date

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