The four-page memo, obtained by The Washington Post from the Library of Congress, sheds light on how Kavanaugh’s thinking evolved on the legal rights of sitting presidents.

His handling of Starr’s Foster probe helped elevate Kavanaugh’s career, but the lengthy inquiry enabled conspiracy theories to flourish and add to the tumult of the Clinton presidency. Once the Foster matter was closed, Starr’s office continued to investigate the Clintons and eventually veered into the president’s relationship with White House intern Monica Lewinsky.

Kavanaugh pursued the Foster inquiry at Starr’s request, even though he and others in the office soon came to believe that Foster killed himself, according to two people who worked with him at the time. Ultimately, Kavanaugh’s report in October 1997 affirmed earlier findings of suicide. The Foster component of Starr’s investigation cost about $2 million and lasted three years.