Manafort’s sentence should reflect the “gravity of his conduct," prosecutors wrote, before ticking off the extensive list of offices and people to whom Manafort is accused of lying.
“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,” prosecutors wrote in a sentencing memorandum for Manafort in his Washington, D.C., case.
The former chairman of President Donald Trump's election campaign is facing up to 10 years in prison in one case in D.C. and up to 25 years in another case in Virginia, according to statutory maximums.
In Virginia, where Manafort faced charges of tax and bank fraud, a jury found Manafort guilty on eight counts in August. On the eve of a second trial in Washington, D.C., in September, Manafort pleaded guilty to two counts of conspiracy and agreed to cooperate with prosecutors.
But that plea deal fell apart after the special counsel’s office accused Manafort of continuing to tell lies after agreeing to cooperate, actions which prosecutors say amounted to a breach of his agreement.
In Saturday's memo, the special counsel's team also declined to take a position on whether the prison sentence in the D.C. case should run concurrently or consecutively with his sentences in the Virginia case -- but reserved their right to submit a recommendation at sentencing next month.
The defense counsel claims Manafort did not intentionally lie, but the federal judge overseeing his case sided with prosecutors earlier this month.
Prosecutors on the special counsel's team encouraged Judge Amy Berman Jackson not to consider Manafort’s short-lived cooperation at sentencing, arguing that his lies negate any leniency he may have otherwise earned.
The special counsel’s office in its sentencing memorandum reprimanded Manafort on his breach of plea deal, saying his lies showed "hardened adherence to crimes and lack of remorse."
Mueller's team said that Manafort's attempt to "not be held accountable for his crimes" by tampering with witnesses a matter that "went to the heart of the criminal justice system."
"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 Mueller team wrote in Saturday's memo. "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."
"Even after he purportedly agreed to cooperate with the government in September 2018, Manafort, as this court found, lied to the Federal Bureau of Investigation (FBI), this office, and the grand jury."
Prosecutors noted in the filing that Manafort committed crimes during the campaign including his illegal Ukraine lobbying with his associate Konstantin Kilimnik, and after he had been indicted, including witness tampering and lying to prosecutors after he had signed a plea deal with prosecutors.
In a sentencing memo filed in the Virginia case last week, the special counsel agreed with the findings of an independent pre-sentence report, which calculated that Manafort’s crimes call for a prison sentence of up to 25 years. Prosecutors stopped short of taking a position of their own on a suggested prison term in this case.
Manafort is scheduled for sentencing in both cases next month.