The 13-page document aims to identify for Mueller what the lawyers believe are grievous errors both in how Comey handled the Clinton investigation and in his early, and limited, encounters with the president. In it, Kasowitz argues that Comey cannot be trusted as a witness because he repeatedly embellished his testimony before Congress, put his “own personal interests and emotions” above FBI protocol and left a cloud of undue suspicion above the president’s head.

“Over the last year, Mr. Comey has engaged in a pattern of calculated unilateral action unbounded by governing law, regulation and practice, and plainly motivated by personal and political self-interest,” wrote Kasowitz, who has since stepped aside as lead lawyer.