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Just four days before he left office, President Bush instructed former White House aide Karl Rove to refuse to cooperate with future congressional inquiries into alleged misconduct during his administration.
On Jan. 16, 2009, then White House Counsel Fred Fielding sent a letter (.pdf) to Rove's lawyer, Robert Luskin. The message: should his client receive any future subpoenas, Rove "should not appear before Congress" or turn over any documents relating to his time in the White House.