BY FAX AND U.S. MAIL

Mr. Fred F. Fielding

Counsel to the President

Office of the Counsel to the President

The White House

1600 Pennsylvania Avenue, N.W.

Washington, D.C. 20530

Dear Mr. Fielding:

I am disappointed that the President's Chief of Staff Josh Bolten has continued to disobey the subpoena served on him on June 13, 2007, and has not produced the documents called for by that subpoena. Enclosed with this letter is a copy of the text of a ruling by Chairwoman Sanchez at today's meeting of the Subcommittee on Commercial and Administrative Law rejecting the claims of privilege that you have sought to raise in response to that subpoena. The ruling was sustained by a 7-3 vote of the Subcommittee.