Back to the 70s
This seems to cover it pretty well:
Would the U.S. Attorney for the District of Columbia -- appointed by Gonzales under the infamous and now-repealed provision of the PATRIOT Act -- refuse to prosecute the White House and the Department of Justice for failing to produce the subpoenaed e-mails, or for destroying them? Well, it's happened before. Back in the 80s, the Reagan DoJ refused to prosecute EPA Administrator Anne Gorsuch Burford for her contempt of Congress charges, and even filed suit against the House of Representatives to block the enforcement of their subpoenas.
So what we have here is not just an 18-minute gap, but a case where Archibald Cox has already been fired. We've already had our Saturday Night Massacre.
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