Former campaign manager for President Donald Trump, Paul Manafort (right), leaves U.S. District Court after pleading not guilty following his indictment on federal charges. | Win McNamee/Getty Images Manafort defense blasts indictment as based on 'tenuous legal theory' Filing also notes Ukraine work predated his Trump campaign role by two years

Lawyers for former Trump campaign chairman Paul Manafort argued Thursday that the case against him is based on dubious legal theories and that there is no need for him to post millions of dollars in collateral to ensure he will appear for trial.

Manafort's legal team filed its first substantive pleading in the criminal case, arguing that prosecutors constructed a money laundering case against Manafort and his business partner Rick Gates because the real issue — whether they broke the law by failing to register foreign agents for Ukraine — was too uncertain.


"It is far from clear what activity triggers a requirement to file a report as a foreign agent. In order to conceal this weakness in the Indictment, a façade of money laundering has been put forth using a tenuous legal theory," lawyers Kevin Downing and Tom Zehnle wrote. "The weight of the evidence outlined against Mr. Manafort has also been embellished."

Manafort's attorney also said the Ukraine-related work that is the focus of the indictment was completed before the veteran lobbyist spent several months as Trump's campaign chief in mid 2016, though it is not clear why that is important to the court.

A magistrate judge released Manafort and his business partner Rick Gates on Monday on the condition that they be confined to their homes, with limited exceptions for legal meetings, court appearances, medical appointments and religious observances. Gates' legal team asked Thursday for his home confinement to be lifted.

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Prosecutors alleged in a court filing Wednesday that Manafort has valued his worth in amounts ranging from $25 million to $136 million. Manafort agreed to a $10 million personal recognizance bond, which essentially means he would forfeit that amount if he fails to come to court as required. But prosecutors indicated they would seek some assets to back up that bond.

Manafort's defense said he shouldn't have to pledge any specific assets, arguing that he is not likely to try to run.

"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," Downing and Zehnle wrote. "This is an imagined risk; it is not real."

The defense said intense media coverage of the case and special counsel Robert Mueller's investigation make it impractical for Manafort to flee anyway.

"Given the substantial media coverage surrounding Mr. Manafort and this investigation, it is fair to say that he is one of the most recognizable people on the planet today. Query where such an individual could even hide?" a footnote in the pleading says.

While the prosecution had pointed out that Manafort traveled to Mexico, China and Ecuador earlier this year and took with him a phone registered under an alias, the defense noted something else about those trips: he came back.

"His former counsel was told by the Government prosecutors in August that they were going to indict him. During this investigation period, Mr. Manafort traveled overseas on business and, to no one’s surprise, he returned to the United States," the filing says.

Manafort and Gates are scheduled to appear at 2 P.M. Thursday for the first hearing before U.S. District Court Judge Amy Berman Jackson.

