Lawyers for former Trump campaign chairman Paul Manafort called him “one of the most recognizable people on the planet” in a court filing Thursday pushing back on Special Counsel Robert Mueller’s claims that he is a flight risk.

Manafort, indicted on federal charges of tax evasion, money laundering, and failure to disclose foreign lobbying as part of Mueller’s Russia probe, is scheduled to appear court Thursday afternoon. Among the issues for the judge are the conditions of Manafort’s release from the home confinement he has been in since turning himself in on Monday.

His lawyers’ filing Thursday accused the government of ignoring Manafort’s “strong family ties” in calling him a serious flight risk.

“Apparently, the Government Memorandum seeks to persuade this Court that Mr. Manafort is a serious risk to simply up and leave his wife of almost 40 years, his two daughters, and his grandchildren, so that he can live the rest of his life on the lam,” it said. “This is an imagined risk; it is not real.”

The filing also revealed that Manafort’s former attorney was told by Mueller’s team in August that they planned on indicting him — a communication that was previously reported by the New York Times. His lawyers argued Thursday that he did not choose to flee the country then.

“During this investigation period, Mr. Manafort traveled overseas on business and, to no one’s surprise, he returned to the United States,” the court document said.

The filing took issue with many of the allegations in Mueller’s original indictment and responded to some of the concerns raised by a subsequent Mueller filing about Manafort holding three U.S. passports.

“Although it might be surprising to some, it is perfectly permissible to have more than one U.S. passport, as individuals who travel abroad extensively no doubt know. Mr. Manafort has strong family and community ties and does not pose a serious risk of flight,” Manafort’s lawyers said Thursday.

(A State Department official told TPM Wednesday that it allows the issuance of more than one passport on a case-by-case basis. Rich Mandleur, the CEO of the passport expediting service Passport Visas Express, told TPM that while some frequent travelers hold two passports at a time, he had never in his 18-year career heard of someone being allowed to hold three passports at time.)

Manafort’s lawyers argued that the $10 million unsecured appearance bond that was set earlier this week “will more than suffice to assure his appearance as required.”

Read the filing below: