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Article 3 of Nixon's impeachment was obstruction of Congress, refusing to obey defined congressional subpoenas, pleading imaginary privilege, and obviously that's what The President has been doing. Richard Nixon wasn't foolish to say in advance that Richard Nixon's going to defy all congressional subpoenas... and today we saw a witness instructed by the White House completely contemptuous of Congress who refused to answer relevant questions. Just another instance of obstruction of Congress and that's what Article 3 of the Richard Nixon impeachment was.

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