It's possible Manafort's legal team filed the entire document under seal, though with that approach they'd normally announce their intention to keep secret the filing in the case docket. Despite the deadline, the public record of Manafort's criminal case in DC District Court has not been updated since mid-December.
Manafort's legal team did not respond to an inquiry after midnight Tuesday about whether the document was filed, nor did a spokesperson for the special counsel's office. The judge overseeing the case has not yet weighed in as of Tuesday morning.
Last month, Mueller said the former Trump campaign chairman lied about five major issues after agreeing to cooperate with prosecutors, including his "contact with administration officials" and his interactions with Konstantin Kilimnik, who is tied to the Russian military intelligence unit accused of hacking Democrats.
Kilimnik has denied working for Russian intelligence. Manafort denies colluding with any Russians. Kilimnik and Manafort were charged with obstruction of justice in June for trying to influence witnesses who could testify at Manafort's trial. Manafort pleaded guilty to obstruction in September, but Kilimnik lives safely in Russia, out of the reach of US courts.
Court watchers and the judge anticipated that the Manafort team would either push back on Robert Mueller's team's assertions—like they previously indicated they would—or agree not to fight the special counsel as Manafort headed to sentencing. His sentencing is currently set for March, but the judge who will sentence him planned to first resolve whether he did indeed breach his plea agreement with prosecutors. A public hearing is scheduled on that question for later this month.
The lack of public response from the Manafort team leaves the case at a cliffhanger following a series of twists -- from Manafort being sent to jail, through his conviction at trial and decisions to flip, cooperate with Mueller, then split with the special counsel's office.
At one time earlier in the criminal case, Manafort's attorneys asked the judge minutes before midnight for a filing extension.
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