Manafort “is presented to this Court by the government as a hardened criminal who ‘brazenly’ violated the law and deserves no mercy. But this case is not about murder, drug cartels, organized crime, the Madoff Ponzi scheme or the collapse of Enron,” the attorneys wrote in a memo filed in U.S. District Court in Washington.

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“The Special Counsel’s attempt to portray him as a lifelong and irredeemable felon is beyond the pale and grossly overstates the facts before this Court,” the attorneys wrote.

The defense said Manafort was unduly singled out for prosecution by the special counsel’s office for “garden-variety” financial crimes and “esoteric” foreign lobbying disclosure violations but not, they said, on charges that showed any links between the Russian government or individuals and the campaign.

“As said at the beginning of the case,” his attorney wrote to Judge Amy Berman Jackson, “there is no evidence of Russian collusion.”

The defense filing came after a weekend sentencing memo by special counsel Robert S. Mueller III’s team that recommended no specific sentence for Manafort, but called him a bold, “hardened” criminal who “repeatedly and brazenly violated the law.”

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In a September plea deal, Manafort, 69, acknowledged that he was guilty of all conduct he was accused of in both Washington and Virginia: making tens of millions as an unregistered lobbyist for Ukrainian politicians over a decade, hiding that money to avoid paying taxes, defrauding banks to pay his debts when his oligarch patrons fell out of power and lying to cover up his crimes while trying to persuade wit­nesses to do the same.

He was convicted at a federal trial in Virginia in August.

Manafort’s lawyers in the Monday filing gave what appeared to be his first explanation of his admission to bank fraud, saying his actions “stemmed from a desire to maintain his assets in the face of what he hoped and believed would be a temporary financial setback” after the loss of his Ukrainian patron.

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Both federal cases against him stemmed from Mueller’s investigation and the court filings set the stage for Manafort to be sentenced early next month, as Mueller is expected to wrap up his probe.

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The two wide-ranging conspiracy charges to which Manafort pleaded guilty in Washington carry a maximum sentence of 10 years.

Mueller prosecutors reserved the right at sentencing March 13 to ask Jackson to impose a punishment that runs on top of any prison time Manafort is sentenced to for related crimes in a Virginia federal court.

Manafort’s attorneys asked for any sentences to run concurrently. “In light of his age and health concerns, a significant additional period of incarceration will likely amount to a life sentence for a first time offender,” wrote attorneys Kevin M. Downing, Thomas E. Zehnle and Richard W. Westling.

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Manafort faces a separate sentencing March 8 in federal court in Alexandria, Va. He was found guilty of eight counts of bank and tax fraud at trial, and federal guidelines in that case call for him to be sentenced to roughly 19 to 24 years.

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As with Jackson, Mueller prosecutors in Alexandria made no specific sentencing request and asked only that U.S. District Judge T.S. Ellis III hand down a sentence reflecting “the seriousness of these crimes.”

The flurry of activity comes as the Justice Department, under newly confirmed Attorney General William P. Barr, is readying for Mueller to formally conclude his work. Mueller’s office has teamed with U.S. attorney’s offices for the District and elsewhere to take over pending legal matters as required.

Under his plea agreement in Washington, Manafort admitted to all indicted conduct on reduced charges of conspiracy, in exchange for a possible request for leniency if he cooperated fully and told the government about “his participation in and knowledge of all criminal activities.”

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But Mueller prosecutors in November accused Manafort of breaching the deal by lying, and Jackson earlier this month agreed, finding that Manafort had lied repeatedly about his interactions with Konstantin Kilimnik, a longtime aide whom the FBI assessed to have ties to Russian intelligence.

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Those contacts, prosecutors said in court, go “very much to the heart of what the special counsel’s office is investigating.”

Among his lies, Manafort gave inconsistent accounts of an August 2016 meeting in New York City at which he and Kilimnik discussed a peace plan for Ukraine, a top foreign policy priority for Russia. At the time, Manafort was still leading Trump’s campaign. He also lied about sharing polling data with Kilimnik in 2016, prosecutors said in describing how he broke his deal to cooperate truthfully.

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The judge also concluded that Manafort had lied on two other counts: about a payment that he claimed was a loan, and as part of another Justice Department investigation whose focus has not been described publicly.

Manafort’s lawyers in their sentencing memo said Manafort acknowledged that conspiring with Kilimnik to attempt to tamper with witnesses was wrong, but his lawyers said the conduct consisted of a “handful of short or ignored telephone calls and text messages,” unlike “most witness tampering cases” involving offers of bribes, financial incentives or threats of physical harm.

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In 2017, Kilimnik denied to The Washington Post having connections to Russian intelligence.

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