Former Trump campaign chairman Paul Manafort responded to special counsel Robert Mueller’s claims he lied to investigators with a court filing posted Tuesday that said Manafort “provided complete and truthful information to the best of his ability.”



“He attempted to live up to the requirements of his cooperation agreement and provided meaningful cooperation relating to several key areas under current government investigation,” the court filing said.

Manafort’s attorneys appear to have made a mistake in the filing, allowing redacted portions to be revealed via copying and pasting the text to a new document. Most of what’s revealed relates to Manafort associate Konstantin Kilimnik, a Russian national who Mueller has linked to a Russian intel agency. Manafort’s attorneys write that he “conceded” to special counsel prosecutors that he discussed a “Ukraine peace plan” with Kilimnik “on more than one occasion,” and that he is accused of lying to the government about “sharing polling data with Mr. Kilimnik related to the 2016 presidential campaign.”

The redacted sections also revealed that Manafort and Kilimnik met in Madrid. The court filing does not say when that meeting occurred. But an unredacted section that follows stresses that is not uncommon to for witnesses to fail to give a complete recollection of events and that “these occurrences happened during a period when Mr. Manafort was managing a U.S. presidential campaign and had countless meetings, email communications, and other interactions with many different individuals, and traveled frequently.”

Another redacted portion reveals more details about alleged contacts Manafort has had with Trump administration officials. The filing said that an unknown individual texted Manafort about invoking his name if the individual met President Trump. “This does not constitute outreach by Mr. Manafort to the President,” a redacted line in the filing claims, while another redacted sentence says another alleged interaction is “hearsay purportedly offered by an undisclosed third party.”

The alleged misstatements, “to the extent they occurred at all, were not intentional,” Manafort’s lawyers told the court.

Despite their dispute of the allegation that he lied after coming to a plea deal with prosecutors, Manafort’s attorneys said in the filing that they are not requesting an evidentiary hearing on the claims. U.S. District Judge Amy Berman Jackson had said she might hold such a hearing this month if she found it necessary, and in a brief order issued after the filing was posted, the judge said that she would decide whether to hold a hearing.

Instead, Manafort suggested that the matter be addressed in the pre-sentencing report compiled by the probation office.

A hearing could be called after the report if factual disputes remain, Manafort’s filing said.

The court filing outlines Manafort’s routine on days that he sat for interviews with investigators — which included awaking “before dawn” and answering questions for “many hours” and “usually the entire day” — as well as the health conditions, including gout, “depression and anxiety,” he is suffering from while in confinement. It also notes that he was not given a chance to review relevant documents that could have refreshed his memory before the interviews, while conceding that prosecutors aren’t required to make such materials available to a cooperating defendant.

The filing addressed specifically Mueller’s allegation that he misled investigators on he and Kilimnik’s efforts to engage in witness tampering after he was indicted. His attorneys claimed Manafort simply “balked” at characterizing Kilimnik’s state of mind, in response to an investigator’s questions.

The filing chalks alleged misstatements about a payment made on Manafort’s behalf to “confusion,” and said that it was unclear to Manafort how it was recorded by his accountants. A redacted sentence says that prosecutors have not provided Manafort witness statements that are inconsistent with his account, despite claiming there are inconsistencies.

When addressing claims that Manafort misled investigators interviewing him as part of a seperate, unspecified Justice Department investigating, the filing says that Manafort corrected the allegedly inconsistent statements during the same interview session, once he was able to look at notes from a prior interview with investigators.

Read the court filing below: