The latest filing, which was redacted and unsealed Saturday, pertains to two charges of conspiracy Manafort pleaded guilty to last year. But that plea deal collapsed after a judge ruled Manafort intentionally lied to Mueller's office, the FBI and the grand jury. Friday's court document builds on another sentencing memo for Manafort, which Mueller filed last week in the Eastern District of Virginia (EDVA), where he will be sentenced for eight felonies related to financial fraud. Several details of the new filing stand out and give insight into Mueller's long engagement with Manafort, and what might come next. Here are five takeaways:
1. Mueller slams Manafort.
Mueller shows no mercy in this memo. He excoriates Manafort for "repeatedly and knowingly" breaking the law. The sentencing memo also states "his criminal actions were bold" and went to "the heart of the criminal justice system," with "no warranted mitigating factors." In one particularly devastating passage, Mueller lists the many people and entities Manafort has lied 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." Ouch.
2. Manafort will spend most or all of his remaining life in jail.
In the prior EDVA sentencing memo, Mueller calculated that Manafort's sentencing range falls between 19 and 24 years. Saturday's sentencing memo may add to that total. While Mueller does not request a specific sentence in the newly-filed memo, Manafort faces a maximum sentence of 10 years in Washington. It remains unclear whether that sentence will run concurrently (at the same time as) or consecutively (tacked on the end) to his sentence in EDVA. Even assuming Manafort's sentence falls at the low end of the EDVA range, and that Saturday's filing adds nothing to that, Manafort -- who turns 70 years old in April -- will be in prison until his late 80s.
3 (Unless...)
Having sabotaged his own chance at redemption -- or, more pragmatically, at a sentencing reduction -- by lying during his failed attempt to cooperate with Mueller, Manafort now has only one out left: a presidential pardon. Mueller's team previously told the judge that Manafort lied to Mueller "to at least augment his chances for a pardon" and President Trump has previously expressed his sympathy for Manafort in a tweet professing his "respect for a brave man!" The New York attorney general has reportedly prepared tax charges against Manafort as a potential countermeasure, because a president cannot issue pardons for state-level crimes.
4. There's still lots of black ink.
Some of the redactions in the memo seem to protect the identities of people or companies who did business with Manafort, even though there are plenty of other names in the document that were released. Mueller may have ongoing business involving the names that have been blacked out. The memo also contains larger blocks of redaction, including one that runs over a full page uninterrupted. That suggests that Mueller still has open investigations relating to Manafort and others. While Mueller will reportedly wrap up his work soon, he will will pass ongoing investigations to other facets of the DOJ, including the Southern District of New York. This isn't over.
5. This is not the Mueller report.
While the new sentencing memo -- viewed alongside the one filed in EDVA last week -- paints a vivid picture of Manafort's dizzying array of criminal conduct, it remains narrowly focused. The memo does not take detours, nor does it go out of its way to implicate others. It drives home a singular message: Manafort's conduct has been egregious and he deserves to go to prison for a long time. Mueller does not try to tell the whole story of his investigation here. For that we may have to wait a little longer.
The most recent memo cements Manafort's ignominious place in history. Based on what we know right now -- and there certainly is more to come -- Manafort has committed more serious crimes than any other person in Trump's orbit.
He defrauded the US government of millions of dollars; he stole money from banks through a complex fraud scheme; he worked as an unregistered foreign agent -- a spy -- and took deceptive measures to hide his work from the US government; he tried to tamper with witnesses; and he lied to nearly everybody along the way. In addition to the crimes he has been convicted of, we know Manafort also gave secret internal polling data from the Trump campaign to a businessman linked to Russian intelligence. And of course, he and Trump's son and son-in-law met in Trump Tower with Russians offering dirt on Hillary Clinton in 2016.
Here is what we should not lose sight of amid court filings and new revelations: Donald J. Trump chose Paul Manafort as his campaign chairman. Despite claims that Manafort worked for him "for a very short time," Trump hired Manafort to work on his campaign for a crucial five-month stretch from March to August 2016. And for three of those months, Manafort worked as Trump's campaign chairman.
One of the most important remaining questions is whether Trump knew about or directed Manafort's conduct. Even if Trump was somehow completely blind to the history and conduct of the man he chose to lead his campaign, Manafort will nonetheless remain a permanent stain on Trump's legacy and this country's history.
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