Paul Manafort: Government's submission in support of its breach determination

Source: Courtlistener.com

RESPONSE TO ORDER OF THE COURT by USA as to PAUL J. MANAFORT, JR re Order on Sealed Motion for Leave to File Document Under Seal,, REDACTED Submission in Support of Breach Determination (Weissmann, Andrew) (Entered: 12/07/2018)

The United States of America, by and through Special Counsel Robert S.
Mueller, III, respectfully makes this submission to summarize the basis for its
determination that defendant Paul J. Manafort, Jr., has breached his plea agreement
by making false statements The government intends to rely on the defendant's false
statements as a sentencing issue under 18 U.S.C. 3553. We are prepared to prove
the basis for the defendant's breach at a hearing that will establish each false
statement through independent documentary and testimonial evidence, including
Manafort's subsequent admissions We separately submit a motion to permit filing
under seal the factual material that relates to pending investigations or uncharged
individuals.

A. Factual Background

On September 14, 2018, Manafort pleaded guilty to a superseding information,
charging him With two conspiracy counts that together encompassed all the criminal
conduct alleged in the superseding indictment in this district. As the Court is aware,
that criminal conduct occurred for more than a decade and up through April 2018.

Manafort's plea agreement required that he cooperate "fully, truthfully,
completely, and forthrightly" with the government Plea Agreement, Doc. 422 11 8;
Plea Hr'g Tr. 39:10-17, 48:11-16, Sept. 14, 2018. The plea agreement further provides
that if the defendant fails "specifically to perform or to fulfill completely each and
every one" of his obligations under the agreement, or "engages in any criminal activity
prior to sentencing or during his cooperation," the defendant will be in breach of the
agreement.

Read more: https://www.courtlistener.com/docket/6183591/460/united-states-v-manafort/

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This is the Court Listener's text made from the scanned 10 page PDF. The link to the actual PDF is here:


https://www.courtlistener.com/recap/gov.uscourts.dcd.190597/gov.uscourts.dcd.190597.460.0.pdf

Among other things, the document (page 9) says that Manafort lied about having contacts with the Trump administration -- contacts as recently as May 2018!
A search of his electronic documents showed other contacts with "Administration officials."

It also said he lied about interactions with Konstantin Kilimnik, and also about some other, unnamed Justice Department investigation.