Except, none of these meetings nor his writings were done on official business. Unless you believe that simply being the FBI director means that every encounter he has is considered official business.
Wait a second, the conversations he admits were all pertaining to his official capacity, even the one with Trump asking for Comey to give Flynn a break because he is a “good guy” is specifically about Comey’s official capacity as the FBI Director and one of the investigations he was conducting.
So all official business.
As he stated, he wrote these memos out on his time after encounters that the President engaged him with.
All concerning official communications with the president, he says himself he had no desire for social interactions with Trump, so by that definition he sees all conversations with the president as official. He said even the request for lenience was from the President to the FBI director and he felt it was not appropriate so all of it is official correspondence, not private, so anything produced from those official meetings is work product and belongs to the Federal Government.
On top of that, he admits he took those memos to work and discussed them with other FBI officials and debated how to react to them. All of it is official.
Since the President was not under investigation and Comey was not briefing the President on any matters of concern for him none of it falls into the realm of being work related.
Bull. They were discussing official investigations, under title 2 Trump has authority over all investigations and Comey even admitted today under oath that Trump had the right to end or start any investigation if he wanted to so even if Trump had ordered the investigation to be concluded for Flynn, that was not illegal in any way.
Don’t forget the president can pardon anyone he wants, previous Presidents have pardoned terrorists and murderers.
But it is beyond childish to try and claim the memos were not concerning official business, all of it was official business, even Trump asking for loyalty would be loyalty under his official capacity as the FBI Director.