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Special counsel replies to Manafort sentencing memo, saying he didn't provide "complete and honest cooperation"

Manafort's lawyers request lighter sentence

The special counsel's office submitted a response to Paul Manafort's sentencing memo objecting to prosecutors' recommended prison sentence, saying that President Trump's former campaign chairman has a history of criminal conduct which should not be overlooked.

Manafort has requested a "significantly" lower sentence for his conviction in the Eastern District of Virginia than sentencing guidelines prescribe. His attorneys argued in a sentencing memo filed Friday that the sentencing range of 19 1/2 to 24 years in prison is "clearly disproportionate" to his offenses as a first-time offender and given "the nature of the offenses." He was convicted of charges including tax fraud and bank fraud last year.

In their response released Tuesday, prosecutors tried to explain to the court why Manafort should not receive a sentence less than commensurate with his crimes, reiterating his criminal conduct and arguing he should receive no credit for pleading guilty in Washington, D.C.

"He neither pled promptly nor provided complete and honest cooperation. He also has not paid back any of the taxes owed," the memo said. Manafort, according to the filing, still owes the U.S. Treasury over $6 million. 

Prosecutors also argued that even though Manafort admitted his guilt in his plea agreement in D.C., he was found by the judge there to have violated that plea agreement.

The memo pushed back against any assertion that Manafort's cooperation should reduce his sentence, contending that "consideration of his lies to the government and grand jury are aggravating factors and an additional basis for the denial of any reduction for acceptance of responsibility."

Prosecutors also believe Manafort still poses a risk of recidivism, noting that he lied to the government and the grand jury as recently as last year. "Such actions are inconsistent with learning any positive lesson from his criminal conduct and proof that the defendant poses a serious risk of recidivism."

Special Counsel Robert Mueller released a sentencing memo in the case against Manafort in Washington, D.C., describing "bold" criminal actions by Manafort in a lengthy new memo in February. The sentencing guideline range for Manafort is 210 months to 262 months, or 17 1/2 to nearly 22 years.

"Manafort chose repeatedly and knowingly to violate the law — whether the laws proscribed garden-variety crimes such as tax fraud, money laundering, obstruction of justice, and bank fraud, or more esoteric laws that he nevertheless was intimately familiar with, such as the Foreign Agents Registration Act (FARA)," Mueller's memo read. "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."

Manafort was originally to be tried in two different cases, one in Virginia and one in the District. He was tried in Virginia, but made a plea deal to avoid the second trial. He was found by the judge in the District case to have breached his plea agreement by lying to the government.

Manafort is scheduled to be sentenced in Virginia on Thursday.

Emily Tillett and Kathryn Watson contributed to this report