"Mueller reports that after the news broke that Trump had sought to get then–White House Counsel to fire the special counsel, Trump sought to get McGahn to deny the story. He also sought to get him to create an internal record denying the story. ...It is hard to imagine a plausible defense based on the idea that pressuring an employee to create false government records by way of influencing his ability to tell the truth is within the president’s constitutional authority."
January 1, 1970
https://en.wikiquote.org/wiki/Mueller_Report