Paul Manafort’s legal team is asking for leniency for President Trump’s former campaign manager and former political consultant to Ukrainian oligarchs with a penchant for ostrich leather. In a sentencing memo filed in federal court Monday, Manafort’s legal team did not dispute his guilt — on a raft of crimes including money laundering, tax evasion and conspiracy — but argue that his crimes “do not warrant a substantial period of imprisonment.”

For its part, the government has argued for significant jail time that would likely amount to a life sentence, noting that the 69-year-old’s misconduct continued even after he was under indictment, and resulted in the revocation of his plea agreement. In a memo released over the weekend Special Counsel Robert Mueller’s team argued: “The sentence in this case must take into account the gravity of this conduct, and serve both to specifically deter Manafort and generally deter those who would commit a similar series of crimes.”

Below are arguments and excerpts from the memo filed by Manafort legal team pleading with the court for a punishment “significantly below the statutory maximum sentence.”

Hey, he’s not a murderer:

Manafort’s lawyers try to paint his conduct as relatively benign, writing: “This case is not about murder, drug cartels, organized crime, the Madoff Ponzi scheme or the collapse of Enron.” They add: “Mr. Manafort [is] facing what could potentially be a life sentence for underlying activity that, while certainly illegal, unquestionably falls on the less serious end of the spectrum of federal felonies.”

People usually get away with this thing:

Manafort was convicted under a provision of the Foreign Agents Registration Act for failing to register with the U.S. government before working on behalf of Ukrainian oligarchs. His lawyers argue that few people are ever punished under this statute: “Consider: This is only the seventh criminal FARA case brought since 1966.”

Relax, it was just a crime and a cover-up:

Oddly, Manafort’s lawyers attempt to tie up his series of criminal actions over many, many years into one tidy crime package — as though that makes it all less bad: “Mr. Manafort is not the ‘brazen’ criminal that the Special Counsel paints him to be…. [T]he charges against the defendant stem from one operable set of facts: Mr. Manafort made a substantial amount of income working as a political consultant in Ukraine and he failed to report to the government the source and amount of all of the income that he made from those activities. He subsequently attempted to conceal his actions from the authorities.”

C’mon, he’s not really that bad:

In keeping with efforts to downplay Manafort’s career as a criminal, his legal team writes: “Mr. Manafort has admitted his wrongdoing before this Court and awaits judgment. 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.”

Hasn’t he been punished enough?

Over the 47-page memo, Manafort’s legal team highlights the ways in which Manafort has already been punished: “The prosecutions brought against Mr. Manafort have devastated him personally, professionally, and financially. The charges and intense negative media coverage surrounding them have destroyed his career. Mr. Manafort, who was always proud of his ability to provide financial support to his immediate and extended family, is now in the process of forfeiting the vast majority of his assets in order to make amends. A lengthy jail sentence is not called for in this case and would not further the statutory goals of sentencing.”

Look, the guy was literally an altar boy:

The sentencing memo offers up myriad character witnesses — including going back to Manafort’s boyhood to underscore what a good fellow he is at heart: “Mr. Manafort’s friend from elementary school, Bart Mazzarella, served as an altar boy with Mr. Manafort, played football with him, and recalls that in ninth grade Mr. Manafort became his school’s class president due to ‘his likability and his leadership ability (that was evident even back then).’”

This wasn’t even about Russia!

Manafort’s team takes pains to state that his criminal conduct did not directly stem from the 2016 campaign or go to the heart of the Mueller probe into collusion with the Kremlin: “The Special Counsel’s investigation and prosecution in this case… do not charge him with anything related to Russia collusion or to the presidential campaign.”

He mostly told the truth — until he lied again:

Manafort’s lawyers do not dispute that their client broke his plea deal by lying, but highlight all the times he failed to lie before that: “Mr. Manafort asks the Court to consider the narrow scope of those topics” — his lies — “against more than 50 hours that he spent answering the government’s questions. Given the relatively small number of alleged false statements in the record in comparison to the defendant’s lengthy cooperation sessions, the Special Counsel implicitly accepted the majority of Mr. Manafort’s answers as truthful.”

He is old and sick:

The legal team spends many pages highlighting Manafort’s age and frail health: “Mr. Manafort’s age alone suggests that a lengthy sentence of imprisonment would be particularly deleterious.”

They write that his health has taken a dive in jail:

“Aside from high blood pressure, Mr. Manafort was a relatively healthy 69-year-old man before he was remanded to custody in June 2018, where has been held in protective solitary confinement…. In jail, he has developed severe gout, which causes significant pain and swelling in his right foot…. Mr. Manafort requires a wheelchair to ambulate on bad days, or a cane on ‘good’ days.”

“He suffers from severe anxiety, panic attacks, and a constant feeling of claustrophobia while he is locked alone in his cell each day.”

“Mr. Manafort’s physical, mental, and emotional health, together with his age and his almost nine-month solitary confinement, weigh strongly in favor of a sentence in this case that does not include a lengthy period of incarceration.”

He’s super sorry and won’t do it again:

Manfort’s lawyers insist that their client has learned from these trying times: “He is deeply remorseful, has suffered almost unprecedented public shame, and he and his family will have to live with the collateral consequences of his conduct for the rest of their lives.” They add: “Mr. Manafort has been personally and financially devestated [sic] as a result of his conduct and the forfeiture he has agreed to. There is no reason to believe that a sentence of years in prison is necessary to prevent him from committing further crimes.”