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"obstruction" has a certain legal bite / "inappropriate" might have some sort of legal implication but sort of weak tea really
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Not terribly. But just the facts includes what he "found strange," so encompassing what was going through his mind at the time.
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Which demonstrates that his memo-writing skills have improved in the past twelve months. Also that he had legal counsel vet the memo first.
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It would overstep his role and seriously undermine his credibility to state such a legal conclusion
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Good point.
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