Manafort again emphasized his fragile health, financial losses and personal humiliation, while questioning the motives of his prosecutors.

“Mr. Manafort acknowledges that he received a fair trial before this Court, he accepts the jury’s verdict, and is truly remorseful for his conduct,” his attorneys wrote. But, as they did in D.C., they added that “the Special Counsel’s attempt to vilify Mr. Manafort as a lifelong and irredeemable felon is beyond the pale and grossly overstates the facts.”

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Manafort, 69, was found guilty of stashing the money he made as a lobbyist from Ukrainian oligarchs overseas to avoid taxes and then committing bank fraud to keep up a lavish lifestyle when his patrons lost power. Although jurors could not agree on 10 out of 18 charges, Manafort later admitted full culpability while pleading guilty to related crimes in D.C. federal court.

There was nothing “particularly sophisticated” about Manafort’s crimes, his lawyers say, that would merit harsher treatment.

It was Manafort’s billionaire clients who insisted on paying through foreign bank accounts, they say, although Manafort now admits he then used those accounts to evade taxes by when buying high-end suits and multimillion-dollar homes.

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When the money dried up, Manafort falsified records and lied to banks to keep the cash flowing through loans. But his lawyers argue that there is “no evidence that he purposely sought to inflict financial harm” on the banks and that he failed to keep up with the loans only because the government froze his assets.

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Again Manafort’s lawyers say he was no criminal mastermind, pointing to testimony that he and employee Rick Gates “simply altered Microsoft Word documents to reflect incorrect income information, or they provided the banks with outdated or fabricated information.”

Manafort has previously found a somewhat sympathetic ear in the Virginia case from District Judge T.S. Ellis III. His attorneys even quote the judge to argue that Manafort was singled out by the special counsel so he would help with their probe of Russian involvement in the 2016 presidential election and provide details of President Trump’s campaign.

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“The Special Counsel’s strategy in bringing charges against Mr. Manafort had nothing to do with the Special Counsel’s core mandate — Russian collusion — but was instead designed to ‘tighten the screws’ to compel Mr. Manafort to cooperate and provide incriminating information about others,” they wrote.

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After losing at trial in Virginia, Manafort did plead guilty to related crimes in federal court in Washington and agreed to cooperate with the special counsel.

But the D.C. judge, Amy Berman Jackson, later concluded that Manafort lied repeatedly to investigators. Defense attorneys asked Ellis to draw his own conclusions based on the record as to whether Manafort lied.

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In both Virginia and Washington, Mueller’s team has refrained from asking for any specific punishment for Manafort. But they emphasized that his dishonest conduct spanned years and continued even after his indictment and convictions. He shows, they argued, “a hardened adherence to committing crimes and lack of remorse.”