WASHINGTON (CN) — In a scorching sentencing memo that describes Paul Manafort as an unrepentant serial liar who “presents a grave risk of recidivism,” special prosecutor Robert Mueller told a federal judge that he sees no reason to tread lightly on President Trump’s former campaign chairman.
Mueller filed the redacted 25-page memo on Saturday. Though he does not recommend a specific sentence for Manafort’s two guilty pleas to conspiracy, the tightly written document bludgeons Manafort repeatedly, accusing him of committing "an array of felonies over a decade, up through the fall of 2018."
This behavior, according to the special counsel was deliberate, repetitive and audacious.
"His criminal actions were bold, some of which were committed while under a spotlight due to his work as the campaign chairman and, later, while he was on bail from this court," the memo says. "And the crimes he engaged in while on bail were not minor; they went to the heart of the criminal justice system, namely, tampering with witnesses so he would not be held accountable for his crimes."
Pockmarked with redactions, the memo does not provide any details about Manafort's communication with Russians during the 2016 U.S. presidential campaign, including with his long-time Russian associate Konstantin Kilimnik.
An August 2016 meeting between the pair, along with Trump campaign deputy Rick Gates, at a cigar bar in Manhattan during the peak of the presidential campaign, is reportedly at the heart of the special counsel's investigation, according to court documents.
While the sentencing memo offers no further details about that meeting, it highlights Manafort's ongoing crimes, which the government says didn't stop even after Manafort averted a second criminal trial by pleading guilty to two counts of conspiracy in Washington, D.C., and agreeing to cooperate.
That plea deal collapsed because Manafort lied during his cooperation sessions, including about the nature of his contacts with Kilimnik.
"His deceit, which is a fundamental component of the crimes of conviction and relevant conduct, extended to tax preparers, bookkeepers, banks, the Treasury Department, the Department of Justice National Security Division, the FBI, the Special Counsel’s Office, the grand jury, his own legal counsel, Members of Congress, and members of the executive branch of the United States government," the memo says.
As part of his September plea agreement, Manafort admitted guilt to all the crimes he was accused of in both the Eastern District of Virginia and Washington, D.C.
Both sets of charges stemmed from his unregistered lobbying work on behalf of a pro-Russian political party in Ukraine, for which he earned millions in income that he concealed to evade paying taxes, and which he laundered through offshore accounts.
The special counsel concludes that Manafort poses "a grave risk of recidivism," and that nothing in his background "mitigates his criminality."
On top of his upcoming sentence in the Eastern District of Virginia, where a jury convicted him of financial crimes including bank and tax fraud, Manafort could face additional time from the charges in Washington, D.C.
In Virginia, Manafort's sentencing range under federal guidelines is 19 to 24 years, and he could face up to 10 additional years in the Washington, D.C., case though it's not yet clear whether the latter would run simultaneously or be added onto the Virginia sentence.
Manafort will be sentenced in Virginia on March 8, followed by sentencing in Washington, D.C., on March 13.
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