The Supreme Court nominee fibbed throughout his entire confirmation hearing. Republicans don't seem to care.
You can't even be honest about what a fart is, Mr. Kavanaugh.
You can't even be honest about what a fart is, Mr. Kavanaugh.
POOL New / Reuters

WASHINGTON ― Sen. Jeff Flake (R-Ariz.) said Sunday that if Supreme Court nominee Brett Kavanaugh lied under oath, his nomination is over.

“Oh, yes,” Flake told CBS News’ Scott Pelley.

Well, Senator? Do we have some news for you! Kavanaugh lied throughout his confirmation hearing. He told big lies and easily disprovable small lies. This may not even be the first time he has lied under oath: former Sen. Russ Feingold (D-Wis.) said Kavanaugh lied to him in his 2006 confirmation hearing for his current seat on the U.S. Court of Appeals for the D.C. Circuit.

So, Sen. Flake, we now present to you all the lies Kavanaugh told in last week’s hearing — at least all the ones we can prove.

(A Flake spokeswoman did not respond to a request for comment.)

Christine Blasey Ford’s allegations are ‘refuted’

A key point made by Kavanaugh throughout his defense was that Christine Blasey Ford’s allegations were “refuted” by three contemporaries alleged to have been at the party where she said he sexually assaulted her. Those alleged attendees said, under penalty of perjury, that the event did not take place, Kavanaugh argued.

“Dr. Ford’s allegation is not merely uncorroborated, it is refuted by the very people she says were there, including by a longtime friend of hers,” Kavanaugh said.

“The evidence is not corroborated at the time,” he said at another time. “The witnesses who were there say that it didn’t happen.”

But none of the alleged party attendees ― Mark Judge, Leland Keyser and P.J. Smyth ― ever refuted anything Blasey claimed. They simply said they could not recall attending such a get-together.

“I have no memory of this alleged incident,” Judge said.

“I have no knowledge of the party in question; nor do I have any knowledge of the allegations of improper conduct,” Smyth said.

Keyser said that she has “no recollection of ever being at a party or gathering where [Kavanaugh] was present, with, or without Dr. Ford.” She added that while she can’t remember the event from 36 years ago, she believes Blasey’s allegations. She reiterated this after Kavanaugh’s misleading testimony.

Blasey explained that there was no reason for them to remember the party. “It was not one of their more notorious parties because nothing remarkable happened to them that evening,” she said.

‘Never attended a gathering’ like the one described by Blasey

“I never attended a gathering like the one Dr. Ford describes in her allegation,” Kavanaugh said.

But according to Kavanaugh’s calendars from the summer of 1982, which he submitted as evidence in his defense, he did.

As he said himself, “The calendars show a few weekday gatherings at friends’ houses after a workout or just to meet up and have some beers.” He says that he never attended a gathering like this, but that’s obviously false because the type of gathering he said he did attend is exactly the kind she described.

“None of those gatherings included the group of people that Dr. Ford has identified,” he also said.

On July 1, Kavanaugh wrote that he planned to go “to Timmy’s for skis w/Judge, Tom, PJ, Bernie, Squi.” “Skis” are “brewskis,” a popular slang term for canned or bottled beer in the early 1980s.

So he gathered for brewskis with two of the three people Blasey said she remembers being there. Small gathering? Beer? Judge, Brett and P.J.? Check, check and check.

Brett Kavanaugh's own calendar shows that Christine Blasey Ford's story checks out.
Brett Kavanaugh's own calendar shows that Christine Blasey Ford's story checks out.
The Washington Post via Getty Images

Blasey and Kavanaugh ‘did not travel in the same social circles’

“She attended an independent private school named Holton-Arms, and she was a year behind me,” Kavanaugh said. “She and I did not travel in the same social circles.”

In that July 1 calendar entry about drinking “skis” with friends, he lists “Squi,” the nickname for his high school classmate Chris Garrett. Blasey testified that she briefly “went out with” Garrett in the summer of 1982.

Kavanaugh also admitted in a separate Sept. 17 committee interview that he was friends with Holton-Arms girls. “I would imagine that there were Holton-Arms girls [at parties] on occasion, and I was friends with a couple,” he said.

‘I did not drink beer to the point of blacking out’

“I drank beer with my friends,” Kavanaugh yelled in his opening statement. “Almost everyone did. Sometimes I had too many beers. Sometimes others did. I liked beer. I still like beer. But I did not drink beer to the point of blacking out, and I never sexually assaulted anyone.”

It shouldn’t matter if someone who likes to drink beer or used to binge-drink to the point of blacking out goes on to have a successful career. What is at issue is that Blasey alleged that Kavanaugh was “visibly drunk” when the alleged assault took place. It’s possible Kavanaugh had drunk too much to remember the event.

Kavanaugh repeatedly stated that he has never blacked out in his life. Numerous people who knew him in college and high school said this was likely impossible, based on the number of times they saw him staggering drunk.

“Brett was a sloppy drunk, and I know because I drank with him,” said Dr. Liz Swisher, a college friend of Kavanaugh’s. “I watched him drink more than a lot of people. He’d end up slurring his words, stumbling.”

“He was a notably heavy drinker, even by the standards of the time, and that he became aggressive and belligerent when he was very drunk,” said James Roche, a freshman-year college roommate of Kavanaugh’s. “I did not observe the specific incident in question, but I do remember Brett frequently drinking excessively and becoming incoherently drunk.”

“There is no doubt in my mind that while at Yale, he was a big partier, often drank to excess, and there had to be a number of nights where he does not remember,” said Lynn Brookes, a college classmate.

Kavanaugh and his friends were “loud, obnoxious frat boy-like drunks,” who were the “hardest drinkers on campus,” according to Kit Winter, Kavanaugh’s other freshman-year college roommate.

“I definitely saw him on multiple occasions stumbling drunk where he could not have rational control over his actions or clear recollection of them,” said Daniel Livan, who lived in Kavanaugh’s dorm. “His depiction of himself is inaccurate.”

“The fact is, at Yale, and I can speak to no other times, Brett was a frequent drinker, and a heavy drinker,” said Chad Ludington, a Yale classmate of Kavanaugh’s. “I know because, especially in our first two years of college, I often drank with him. On many occasions I heard Brett slur his words and saw him staggering from alcohol consumption, not all of which was beer.”

Ludington added, “I can unequivocally say that in denying the possibility that he ever blacked out from drinking, and in downplaying the degree and frequency of his drinking, Brett has not told the truth.”

Kavanaugh’s assertion that he has never blacked out from drinking is further challenged by his own stories and emails.

In a 2014 speech at Yale, Kavanaugh recounted his fun partying days with a story about “falling out of the bus onto the front steps of Yale Law School at about 4:45 a.m.” after attending a Red Sox game at Fenway Park. He then admitted that he and a friend had to put together their memory of the drunken night the next day.

“Indeed, as a classmate of mine and I were reminiscing and piecing things together the other day, we think we had more than a few beers before the banquet,” Kavanaugh said.

Kavanaugh, in an email to friends after a fun weekend vacation, apologized for getting belligerent after losing games of dice and said he didn’t remember it happening.

“Excellent time,” reads Kavanaugh’s email dated Sept. 10, 2001. “Apologies to all for missing Friday (good excuse), arriving late Saturday (weak excuse), and growing aggressive after blowing still another game of dice (don’t recall). Reminders to everyone to be very, very vigilant w/r/t confidentiality on all issues and all fronts, including with spouses.” (Emphasis added.)

Kavanaugh told Sen. Sheldon Whitehouse (D-R.I.) that a "boof" is a fart. That's not what Kavanaugh's former classmates said it means.
Kavanaugh told Sen. Sheldon Whitehouse (D-R.I.) that a "boof" is a fart. That's not what Kavanaugh's former classmates said it means.
Alex Wong via Getty Images

‘The drinking age was 18 in Maryland’

“My friends and I sometimes got together and had parties on weekends,” Kavanaugh testified. “The drinking age was 18 in Maryland for most of my time in high school, and was 18 in D.C. for all of my time in high school.”

The legal drinking age was raised to 21 in Maryland when Kavanaugh was 17 years old in 1982, which is when Blasey’s alleged assault took place.

Not only is Kavanaugh wrong about the drinking age when he was in high school; he wasn’t even 18 years old (the incorrect drinking age he claims) when he recorded his own beer drinking on his calendar at the time.

Who cares about a little underage drinking? It wouldn’t matter if this weren’t about two bigger issues: the event in question and whether Kavanaugh is credible. His dishonesty here shows he gets even the little things wrong.

‘Boofs’ and ‘Devil’s Triangle’

“Judge, have you boofed yet?” The question appears on Kavanaugh’s 1983 senior yearbook page. It corresponds with Judge’s page, which says, “Bart, have you boofed yet?” Kavanaugh’s entry includes other terms that refer to heavy drinking (“100 kegs or bust” and “Beach Week Ralph Club”) and a curious phrase, “Devil’s Triangle.”

What does “boof” mean? And “Devil’s Triangle”? The first term “refers to flatulence,” Kavanaugh said in response to Sen. Sheldon Whitehouse (D-R.I.), and the second is a “drinking game” akin to quarters.

But many people, including Kavanaugh’s classmates at Georgetown Prep, said that’s not what those terms mean and that’s not what Kavanaugh was referring to at all. “Boof” has a history of being a slang term for anal sex, and “Devil’s Triangle” refers to sex between two men and one woman.

“Based on extensive interviews by me and @katekelly with Kavanaugh’s former Georgetown Prep classmates, what he just said about the meanings of ‘boofed’ and ‘Devil’s Triangle’ is not true,” tweeted David Enrich, who broke the story about Kavanaugh’s yearbook writings.

‘Renate Alumnius’

In his high school yearbook, Kavanaugh listed himself as a “Renate Alumnius.” (The misspelling of “alumnus” is in the original text.) This was a reference to Renate Dolphin, a female contemporary who attended a Maryland Catholic girls’ school.

“That yearbook reference was clumsily intended to show affection and that she was one of us,” Kavanaugh testified. “But in this circus, the media’s interpreted the term is related to sex. It was not related to sex.”

But two other Georgetown Prep classmates of Kavanaugh’s told The New York Times that it was related to sex. The prep school boys who wrote “Renate Alumnius” in their yearbooks intended it as a claim of conquest ― that they had some kind of physical relations with her.

“They were very disrespectful, at least verbally, with Renate,” Sean Hagan, one of Kavanaugh’s high school classmates, told The New York Times.

Another Georgetown Prep classmate wrote a ditty about Dolphin clearly documenting that their reference was not about friendship: “You need a date / and it’s getting late / so don’t hesitate / to call Renate.” They were saying she was easy.

Dolphin had signed a letter to the committee with 64 other women in support of Kavanaugh after Blasey’s allegations emerged. When the Times contacted her about the “Renate Alumnius” yearbook reference, she said she had not known about it and that it greatly hurt her to learn of it.

“I don’t know what ‘Renate Alumnus’ actually means,” she told the Times. “I can’t begin to comprehend what goes through the minds of 17-year-old boys who write such things, but the insinuation is horrible, hurtful and simply untrue. I pray their daughters are never treated this way. I will have no further comment.”

A statement from Kavanaugh’s lawyer Alexandra Walsh to the Times said that her client and Dolphin attended a high school event once and “shared a brief kiss good night following that event.”

“I think Brett must have me confused with someone else, because I never kissed him,” Dolphin said through a lawyer in response.

And yet Kavanaugh said the reference was “not related to sex” after claiming a kiss that the woman in question denies.

Kavanaugh testified that his yearbook reference to being the biggest contributor to the "Beach Week Ralph Club" was about spicy food making him vomit, not about partying and drinking to the point of puking.
Kavanaugh testified that his yearbook reference to being the biggest contributor to the "Beach Week Ralph Club" was about spicy food making him vomit, not about partying and drinking to the point of puking.
Jim Bourg / Reuters

‘Beach Week Ralph Club, Biggest Contributor’

Kavanaugh listed himself as the biggest contributor to the “Beach Week Ralph Club.” Beach Week is a party week in the D.C.-Maryland-Virginia area where high school students go to nearby beaches to drink heavily. “Ralph” is slang for “vomit.” When Whitehouse asked Kavanaugh about this reference, he said it was about spicy food.

“I’m known to have a weak stomach, and I always have,” Kavanaugh testified. “In fact, the last time I was here, you asked me about having ketchup on spaghetti. I always have had a weak stomach.”

“So the vomiting that you reference in the Ralph Club reference, related to the consumption of alcohol?” Whitehouse followed up.

To which Kavanaugh sputtered a non sequitur reply about how he went to Yale: “Senator, I was at the top of my class academically, busted my butt in school. Captain of the varsity basketball team. Got in Yale College. When I got into Yale College, got into Yale Law School. Worked my tail off.”

“Did it relate to alcohol? You haven’t answered that,” Whitehouse pressed.

“I like beer. I like beer. I don’t know if you do,” Kavanaugh sneered.

“OK,” Whitehouse said, as Kavanaugh weirdly pressed the senator on whether he liked beer and what he preferred to drink.

It is simply laughable to consider that “Beach Week Ralph Club, Biggest Contributor” is in reference to anything other than drinking so much alcohol that one vomits.

‘No connections to Yale’

“I have no connections there,” Kavanaugh insisted regarding his ties to Yale University, where he went as an undergraduate and for law school. “I got there by busting my tail.”

But his grandfather, Everett Edward Kavanaugh, went to Yale for undergrad. The Intercept dug up a copy of his grandfather’s yearbook, showing him as a student.

Yale has said that 20 to 25 percent of its students are classified as legacy students.

No one accused me of sexual misconduct ‘until last week’

“Throughout my 53 years and seven months on this Earth, until last week, no one ever accused me of any kind of sexual misconduct,” Kavanaugh declared in his Sept. 27 hearing.

But Blasey alerted Rep. Anna Eshoo (D-Calif.) and Sen. Dianne Feinstein (D-Calif.), the ranking member on the committee, of her allegations in July. Blasey publicly revealed herself in a Sept. 16 article in The Washington Post.

Mark Judge’s memoir was ‘fictionalized’

Kavanaugh’s friend Judge wrote a book titled “Wasted: Tales of a GenX Drunk,” in which a character named Bart O’Kavanaugh (sound familiar?) vomits on someone’s car during Beach Week and passes out.

Kavanaugh denied that he was the inspiration for O’Kavanaugh. “He wrote a book that is a fictionalized book,” he said in his hearing.

But a note at the beginning of Judge’s book states, “This book is based on actual experiences.”

Judge Alex Kozinski

Kavanaugh repeatedly denied knowing that Judge Alex Kozinski, a mentor for whom Kavanaugh clerked from 1991 to 1992, was a sex predator who harassed women in his office and maintained a private server in his offices for porn. Kozinski is the most important judicial figure, aside from now-retired Justice Anthony Kennedy, in Kavanaugh’s life. Kozinski introduced Kavanaugh when the latter was nominated to the Court of Appeals for the D.C. Circuit.

It’s impossible to know if Kavanaugh provided misleading testimony when he said the revelations about Kozinski were a total surprise and “a gut punch.” But it seems very unlikely.

Kozinski was first accused of “sadistic” and “abusive” behavior in 1985. When the allegations emerged, the Senate Judiciary Committee reopened hearings into his nomination after it already voted to send his nomination to the full Senate. He was still confirmed to the 9th Circuit.

Reports about his harassment of female clerks and his maintenance of a website hosting porn came out in 2008. Kozinski was also known to send to a listserv wildly inappropriate content that demeaned women. He was admonished in 2009 and stepped down as chief judge of the 9th Circuit in 2014. Yet Kavanaugh appeared with Kozinski at a Federalist Society event in 2015.

Kozinski’s behavior was not unknown. Legal reporters Dahlia Lithwick and Ian Millhiser have written that they knew about Kozinski. Yale Law School students told HuffPost that professors Amy Chua and Jed Rubenfeld, who are married to each other, intimated that they avoided clerking with Kozinski because he was known to sexually harass women. Chua is friends with Kavanaugh, has directed multiple students to clerk with him and endorsed his nomination.

Heidi Bond, one of the women who came forward in 2017 to tell their stories of harassment at Kozinski’s hands, wrote in Slate, “Kozinski’s sexual comments — to both men and women — were legendary.”

“Having clerked in his chambers, I do not know how it would be possible to forget something as pervasive as Kozinski’s famously sexual sense of humor or his gag list, as Kavanaugh has professed to in his hearings,” Bond wrote.

Kavanaugh said in his hearing that he could not remember receiving emails from Kozinski’s email list, known as the “Easy Rider Gag List.”

It’s hard to confirm what Kavanaugh knew about Kozinski. It would be possible to find out if he ever received some of those creepy emails Kozinski sent to his listserv, but Kavanaugh did not offer to search his emails to find out.

Sen. Orrin Hatch (R-Utah), a member of the Judiciary Committee, said the sexual assault allegations against Kavanaugh are political "smears."
Sen. Orrin Hatch (R-Utah), a member of the Judiciary Committee, said the sexual assault allegations against Kavanaugh are political "smears."
Chip Somodevilla via Getty Images

William Pryor nomination

William Pryor was nominated by President George W. Bush to the U.S. Court of Appeals for the 11th Circuit in 2003. Pryor, a protege of now–Attorney General Jeff Sessions, was controversial for his views on abortion. Kavanaugh, who handled judicial nominations for the White House at that time, denied that he personally handled Pryor’s nomination when he was questioned during his appeals court confirmation hearings.

“I was not involved in handling his nomination,” Kavanaugh said. “I am familiar generally with Mr. Pryor, but that was not one that I worked on personally.”

But emails showed that Kavanaugh was consulted on Pryor’s nomination.

“How did the Pryor interview go?” Kyle Sampson, a Bush-era Justice Department staffer, emailed Kavanaugh in 2002. “Call me.”

This email did not refute Kavanaugh’s careful testimony, as he said he was “not involved in handling this nomination.” But Democratic senators felt that he misled with his testimony. When he was asked whether he lied or misled about this during his Supreme Court confirmation hearing, he responded, “As I recall at least, I was not the primary person on that.”

Judge Charles Pickering Sr. nomination

During Kavanaugh’s 2006 confirmation hearing for his seat on the D.C. Circuit, he was asked about his role in the Bush White House during the 2001 nomination of Charles Pickering Sr. to a seat on the 5th Circuit. Pickering had solicited letters of support for his nomination from lawyers who had business before his court in Mississippi. Kavanaugh was asked whether he knew about those letters of support.

“My first question is this,” then-Sen. Russ Feingold (D-Wis.) asked Kavanaugh. “Did you know that Judge Pickering planned to solicit letters of support in this manner before he did so? And if not, when did you become aware that Judge Pickering had solicited these letters of support?”

“The answer to the first question, Senator, is no,” Kavanaugh replied. “This was not one of the judicial nominees that I was primarily handling.”

But recently disclosed emails show that Kavanaugh played a significant role in Pickering’s nomination process, which dragged on into 2004 because of a Democratic Party filibuster. Kavanaugh was often the only person included on emails about Pickering’s nomination and helped place op-eds and news stories to help the nominee.

This doesn’t directly refute Kavanaugh’s statement that he wasn’t “primarily handling” the Pickering nomination. Feingold, however, believes he was misled at the time by Kavanaugh.

“Taking all his testimony together, we see a clear pattern emerge: Brett Kavanaugh has never appeared under oath before the U.S. Senate without lying,” Feingold wrote in a HuffPost opinion piece.

Warrantless wiretapping

When Kavanaugh was nominated to serve on the D.C. Circuit Court of Appeals in 2006, he was asked whether he knew anything about the Bush administration’s warrantless wiretapping policy.

Sen. Patrick Leahy (D-Vt.) pressed Kavanaugh on whether he had ever seen “documents relating to the president’s [National Security Agency] warrantless wiretapping program.”

“I learned of that program when there was a New York Times story — reports of that program when there was a New York Times story that came over the wire, I think on a Thursday night in mid-December of [2005],” Kavanaugh said at the time.

Emails that came out during Kavanaugh’s Supreme Court confirmation hearing, however, tell a different story on both accounts.

In the immediate aftermath of the 9/11 attacks, Kavanaugh asked John Yoo, an Office of Legal Counsel lawyer who helped justify warrantless surveillance and torture programs, “Any results yet on the [Fourth Amendment] implications of random/constant surveillance of phone and e-mail conversations of non-citizens who are in the United States when the purpose of the surveillance is to prevent terrorist/criminal violence?”

While Bush did not authorize the NSA surveillance program until 2002, Kavanaugh’s email indicates he was aware of discussions about the program before he said he learned about it from news reports.

Yoo defended Kavanaugh, stating that he was not involved in the development of the NSA program known as Stellarwind.

Sen. Patrick Leahy (D-Vt.) has said Kavanaugh "was not forthright" with him about his access to Democratic strategy documents that Republican aides stole from Leahy in 2003 and passed to George W. Bush’s White House, where Kavanaugh worked. "I’m bothered by it.”
Sen. Patrick Leahy (D-Vt.) has said Kavanaugh "was not forthright" with him about his access to Democratic strategy documents that Republican aides stole from Leahy in 2003 and passed to George W. Bush’s White House, where Kavanaugh worked. "I’m bothered by it.”

Stolen emails

In 2003, Kavanaugh received information based on documents that were stolen from Senate Democrats by a Republican staffer. This included one fully copied stolen document. The documents provided inside information about Democrats’ strategy to oppose Bush’s judicial picks.

Leahy, whose documents were stolen, asked Kavanaugh about this in 2006. He denied knowing the source of the information he received.

Leahy returned to this question during Kavanaugh’s hearing last week ― this time with access to Kavanaugh’s emails from the time. One of those emails included the first draft of a memo composed by Leahy’s staff, although it was not labeled as such. Another came with a subject line of “Spying,” although this one simply suggested the author had a “mole” among Democrats providing intelligence on their strategy.

Leahy pressed Kavanaugh on the draft memo, which he said was “obviously taken from my internal emails.” He asked, “Did any of this raise a red flag in your mind?”

“It did not, Senator, because it all seemed consistent with the usual kind of discussions that happen,” Kavanaugh responded.

As to the question of the “mole” email labeled “Spying,” Kavanaugh chalked it up to bipartisanship, saying, “There was a lot of bipartisanship among the staffs. There were a lot of friendships and relationships where people would talk to — ‘Oh, I’ve got a friend on Sen. Ted Kennedy’s staff’ or ‘I have a friend on Sen. Hatch’s staff or Sen. Specter’s staff.’ That kind of information sharing did not raise red flags.”

Kavanaugh never apologized to Leahy about receiving or using the stolen documents. Leahy concluded, “It’s fair to say that he was not forthright with me, and I’m bothered by it.”

When he learned of Deborah Ramirez’s allegations

Sen. Orrin Hatch (R-Utah) asked Kavanaugh on Sept. 27 when he first learned that Deborah Ramirez, a classmate from Yale, had alleged Kavanaugh once shoved his penis into her face as part of a joke.

“In the last — in the period since then, The New Yorker story,” Kavanaugh replied, referencing the Sept. 23 story about Ramirez’s allegations written by Ronan Farrow and Jane Mayer.

NBC News reported on Oct. 1 that Kavanaugh’s team had reached out to former classmates via text message to get them to rebut Ramirez’s allegations prior to the publication of The New Yorker article.

Two former classmates of Kavanaugh and Ramirez ― Kerry Berchem and Karen Yarasavage ― discussed efforts by Kavanaugh and his lawyers to get Yale classmates to tell the press that the allegations were false.

“In one message, Yarasavage said Kavanaugh asked her to go on the record in his defense,” NBC reported. “Two other messages show communication between Kavanaugh’s team and former classmates in advance of the story.”

Oddly, in a private interview with committee members held on Sept. 25, Kavanaugh indicated that he did know about the allegations before The New Yorker article was published

In the printed transcript of this interview that occurred two days before his public testimony, Kavanaugh complained that Ramirez was calling former classmates to see if they remembered the alleged incident. “And I, at least ― and I, myself, heard about that, that she was doing that,” he said, admitting that he knew about it ahead of time.

It’s not clear why Kavanaugh provided a different response in his public testimony on Sept. 27.

Sucking up to Trump

“No president has ever consulted more widely or talked with more people from more backgrounds to seek input about a Supreme Court nomination,” Kavanaugh said moments after President Donald Trump announced his nomination.

Not only is this an impossible claim to prove ― one would have to review the details of every past president’s vetting process for every Supreme Court nominee ― but it certainly appears that Trump did next to no consulting on his court pick. He was given a list of possible nominees by the Federalist Society, a conservative group that has tremendous sway over Trump’s judicial nominees, and told to pick one.

It took Trump two weeks to pick Kavanaugh from the list. For some contrast, President Barack Obama spent about a month reviewing his options before nominating Sonia Sotomayor and Elena Kagan to the court.

CORRECTION: An earlier version incorrectly noted the location where Trump announced Kavanaugh’s nomination.

This article has been updated to include Kavanaugh response to Ramirez’s allegations.

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