Paul Manafort Lied To FBI After Plea Deal, Mueller Team Alleges

Paul Manafort finds himself in new legal trouble after Special Counsel Robert Mueller accused him of lying after entering a plea agreement.

In a filing with the U.S. District Court late yesterday, the office of Special Counsel Robert Mueller alleged that former Trump campaign manager Paul Manafort, who had reached a plea deal earlier this year that includes an agreement to cooperate with the Special Counsel’s investigation, had lied to investigators. As a result, Mueller’s office is telling the Judge that it’s time to go forward with sentencing: 

WASHINGTON — Paul Manafort, President Trump’s former campaign chairman, repeatedly lied to federal investigators in breach of a plea agreement he signed two months ago, the special counsel’s office said in a court filing late on Monday.

Prosecutors working for the special counsel, Robert S. Mueller III, said Mr. Manafort’s “crimes and lies” about “a variety of subject matters” relieve them of all promises they made to him in the plea agreement. But under the terms of the agreement, Mr. Manafort cannot withdraw his guilty plea.

Defense lawyers disagreed that Mr. Manafort had violated the deal. In the same filing, they said Mr. Manafort had met repeatedly with the special counsel’s office and “believes he has provided truthful information.”

But given the impasse between the two sides, they asked Judge Amy Berman Jackson of the United States District Court for the District of Columbia to set a sentencing date for Mr. Manafort, who has been in solitary confinement in a detention center in Alexandria, Va.

The 11th-hour development in Mr. Manafort’s case is a fresh sign of the special counsel’s aggressive approach in investigating Russia’s interference in the 2016 presidential race and whether anyone in the Trump campaign knew about or assisted Moscow’s effort.

Striking a plea deal with Mr. Manafort in September potentially gave prosecutors access to information that could prove useful to their investigation. But their filing on Monday, a rare step in a plea deal, suggested that they thought Mr. Manafort was withholding details that could be pertinent to the Russia inquiry or other cases.

The question of whether Mr. Trump might pardon Mr. Manafort for his crimes has loomed over his case since he was first indicted a year ago and has lingered as a possibility. A former lawyer for Mr. Trump broached the prospect of a pardon with one of Mr. Manafort’s lawyers last year, raising questions about whether he was trying to influence Mr. Manafort’s decision about whether to cooperate with investigators.

The filing Monday suggested that prosecutors do not consider Mr. Manafort a credible witness. Even if he has provided information that helps them develop criminal cases, by asserting that he repeatedly lied, they could hardly call him to testify.

Mr. Manafort had hoped that in agreeing to cooperate with Mr. Mueller’s team, prosecutors would argue that he deserved a lighter punishment. He is expected to face at least a decade-long prison term for 10 felony counts including financial fraud and conspiracy to obstruct justice.

Instead, after at least a dozen sessions interrogating him, the special counsel’s prosecutors have not only decided Mr. Manafort does not deserve leniency, but they also could seek to refile other charges that they had agreed to dismiss as part of the plea deal.

The prosecutors did not describe what they said Mr. Manafort lied about, saying they would set forth “the nature of the defendant’s crimes and lies” in an upcoming sentencing memo. The sentencing judge does not have to accept the prosecution’s account at face value, and Mr. Manafort’s lawyers are expected to vigorously contest it.

A jury in Northern Virginia convicted Mr. Manafort, 69, of eight counts of financial fraud in August stemming from his work as a political consultant in Ukraine. The jury deadlocked on 10 other charges.

Faced with a second trial in the District of Columbia on related charges in September, he pleaded guilty to two conspiracy counts and agreed to an open-ended arrangement requiring him to answer “fully, truthfully, completely and forthrightly” questions about “any and all matters” of interest to the government.

It was unclear at that time how much Mr. Manafort had to offer prosecutors. Although he had arguably deeper ties to pro-Russian figures than anyone else connected with the Trump campaign, he had consistently said he had no information against the president. Legal experts suggested that if he had been able to significantly further Mr. Mueller’s inquiry, he could have negotiated a more favorable deal.

As it is, the plea agreement specifies that if prosecutors decide that Mr. Manafort has failed to cooperate fully or “given false, misleading or incomplete information or testimony,” they can prosecute him for crimes to which he did not plead guilty in the District of Columbia. They could also conceivably pursue the 10 charges on which the Virginia jury failed to reach a consensus. Mr. Manafort is scheduled to be sentenced in the Virginia case on Feb. 8.

The Washington Post has more:

Prosecutors with special counsel Robert S. Mueller III said Monday that Paul Manafort breached his plea agreement, accusing President Trump’s former campaign chairman of lying repeatedly to them in their investigation into Russian interference in the 2016 election.

Manafort denied doing so intentionally, but both sides agreed in a court filing that U.S. District Judge Amy Berman Jackson of the District should set sentencing immediately.

The apparent collapse of Manafort’s cooperation agreement is the latest stunning turnaround in his case, exposing the longtime Republican consultant to at least a decade behind bars after he pleaded guilty in September to charges of cheating the Internal Revenue Service, violating foreign-lobbying laws and attempting to obstruct justice.

The filing also indicated that Mueller’s team may have lost its potentially most valuable witness in Manafort, a top campaign official present at discussions at the heart of the special counsel’s mission to determine if any Americans conspired with Russia’s efforts to sway the U.S. election.

Still, prosecutors may know more about Manafort’s interactions than he realized, allowing them to catch him in alleged lies.

Separately Monday, conservative author Jerome Corsi, who has ties to a longtime Trump adviser, said he rejected a deal offered by Mueller to plead guilty to one count of perjury because, he said, he did not intentionally lie to investigators.

It was not clear what the men already have told investigators or whether their lack of cooperation would mark a significant setback for Mueller’s investigation.

As part of his plea agreement, Manafort promised to tell the government about “his participation in and knowledge of all criminal activities.” Prosecutors did not elaborate on areas where they contend Manafort lied or what evidence led them to that conclusion. A Mueller spokesman declined to comment.

“After signing the plea agreement, Manafort committed federal crimes by lying to the Federal Bureau of Investigation and the Special Counsel’s Office on a variety of subject matters, which constitute breaches of the agreement,” prosecutors wrote. “The government will file a detailed sentencing submission to the Probation Department and the Court in advance of sentencing that sets forth the nature of the defendant’s crimes and lies.”

Manafort disputes that characterization. His attorneys write in the joint filing that he “has provided information to the government in an effort to live up to his cooperation obligations.”

A Manafort spokesman did not immediately respond to a request for comment.

All of this comes just a few weeks shy of three months after Manafort reached a plea agreement with Mueller’s office rather than face trial in the District of Columbia on charges related to undisclosed foreign lobbying on behalf of a pro-Russian political party and former President of Ukraine. It also comes some four months after Manafort had been convicted in Federal District Court in Northern Virginia. In the District of Columbia case, Manafort pled guilty to two charges that could lead to up to ten years in prison and the Mueller team agreed to drop a number of other charges that could have led to Manafort spending decades in prison if convicted. This would be on top of the sentence he could receive in Virginia for the eight charges on which he had been convicted. Manafort had also agreed to forfeit at least $15 million he had hidden from the IRS and other tax authorities but would have been permitted to keep other properties that are currently held jointly with relatives and other third-parties. With Manafort now at risk of having the entire agreement revoked, he could see the previously dismissed District of Columbia charges, as well as the Virginia charges on which the jury was unable to reach a verdict, reinstated, with the potential that the sentence against him could be enhanced substantially. At the very least, it would mean that Manafort would not receive the recommendation for leniency that could have cut a substantial amount of time off his sentence. Additionally, if he is found to have breached the plea agreement Manafort would lose any credit he might have received under the Federal Sentencing Guidelines and evidence of other crimes could end up being used to increase the potential sentence he faces in the Virginia case.

The filing yesterday doesn’t go into detail regarding what it is that Mueller’s team contends Manafort lied about, but the fact that they have taken this step at all would seem to indicate that they’ve got fairly strong evidence against him and that his lies are substantial and material. Additionally, this development suggests that Mueller’s team has slowly but surely developed a significant amount of evidence to the point where he likely already knew the answer to many of the questions that Manafort was being asked to answer, something that is often the case when one is talking to Federal investigators. In any case, as a general rule, it’s pretty dumb to lie to Federal investigators due to the fact that, pursuant to 18 U.S.C. Sec 1001, such an act is a crime completely separate from any matter that the investigator may be investigating. It is even dumber to lie to Federal investigators when one is operating under the terms of a rather generous plea agreement that is allowing you the possibility of not dying in prison. And yet this is precisely what Manafort appears to have done. Not very smart, Paul.

Here’s the Joint Status Report filed in the case yesterday:

United States v. Manafort J… by on Scribd

FILED UNDER: Law and the Courts, US Politics, , , , , , , , , , , ,
Doug Mataconis
About Doug Mataconis
Doug Mataconis held a B.A. in Political Science from Rutgers University and J.D. from George Mason University School of Law. He joined the staff of OTB in May 2010 and contributed a staggering 16,483 posts before his retirement in January 2020. He passed far too young in July 2021.


  1. OzarkHillbilly says:

    Not very smart, Paul.

    What does one expect from someone who went to work for a billionaire free of charge? Or at least wasn’t getting paid by trump.

  2. drj says:


    What does one expect from someone who went to work for a billionaire free of charge?

    If I recall correctly, Manafort owed a substantial amount of money to a Moscow-connected Ukrainian oligarch. He may not have had much choice in the matter.

    Another thing: last week, Trump submitted his written answers to Mueller.

    Mueller waited until receiving these answers before publicly indicating that he knew (and could prove) that Trump crony Manafort lied.

    It is not far-fetched to assume that there might be a connection. It could well be – for instance, if Manafort and Trump continued to share information – that Mueller now has Trump on lying to the FBI.

  3. Kathy says:

    A liar and a cheat. No wonder El Cheeto likes him.

  4. Daryl and his brother Darryl says:

    According to Guiliani, Dennison and Manafort have a joint defense agreement. I gather this is common practice so that mobsters can get their lies straight, meaning Dennison knows exactly what Manafort has told Mueller. Only now Dennison has answered Mueller’s written questions…in writing…and it makes sense that they jive with Manafort’s answers on similar topics. The catch is that now Mueller knows Dennison was simply telling the same lies as Manafort. All of which would explain Dennison’s Twitter meltdown this morning.

    The Phony Witch Hunt continues, but Mueller and his gang of Angry Dems are only looking at one side, not the other. Wait until it comes out how horribly & viciously they are treating people, ruining lives for them refusing to lie. Mueller is a conflicted prosecutor gone rogue….

    ….The Fake News Media builds Bob Mueller up as a Saint, when in actuality he is the exact opposite. He is doing TREMENDOUS damage to our Criminal Justice System, where he is only looking at one side and not the other. Heroes will come of this, and it won’t be Mueller and his…

    ….terrible Gang of Angry Democrats. Look at their past, and look where they come from. The now $30,000,000 Witch Hunt continues and they’ve got nothing but ruined lives. Where is the Server? Let these terrible people go back to the Clinton Foundation and “Justice” Department!

    $30M? Mueller confiscated more than that from Manafort, so at least he’s profitable!!!
    All pure speculation, of course. No one really knows what Mueller is up to.

  5. CSK says:

    Trump is (or was, yesterday) stoutly maintaining that he, and not his lawyers, wrote the answers to the questions. (Trump’s a moron if he did this, and his lawyers are bigger morons if they let him. Though how do you stop him?) Were Manafort and Trump somehow getting information to each other?

  6. OzarkHillbilly says:

    @drj:Hence, the 2nd part of my comment:

    Or at least wasn’t getting paid by trump.

    I’m pretty sure he got some kind of consideration tho what do you give to a soulless tool I am not sure.

  7. Daryl and his brother Darryl says:

    Gee…I wonder what Manafort could have lied to Mueller about???
    If this article is correct…HOLY FVCK!!!

  8. OzarkHillbilly says:

    @Daryl and his brother Darryl:

    According to Guiliani, Dennison and Manafort have a joint defense agreement.

    Something about a plea agreement offering complete cooperation with the Mueller team makes me think Giuliani is lying (as in I really doubt Mueller and Co would not have put into writing an end to any and all joint defense agreements).

    Not that that means Manafort wouldn’t have tried to pass whatever info he could to trump via his lawyers, which if they did that they are dumber than a box of rocks.

  9. MarkedMan says:

    It’s hard to fathom what goes through the head of someone who signs a plea agreement with the intention of reneging on it. But I guess maybe Manafort felt it was worth a shot. If he came clean, the Russians might have killed him for it. If he didn’t accept the agreement he was looking at spending his life in jail. So maybe it was worth a shot.

    Another explanation is that this is simply who Manafort is – a liar and a thief. I always laugh a bit when someone talks about what someone like Manafort (or Trump or the Catholic Church) should do strategically. These recommendations always start from the assumption that they are innocent and just badly guided. A more useful analysis would be “What would a guilty person be doing? And is that what they are, in fact, doing?”

  10. Kit says:

    Am I completely off base in thinking that Manafort went into this with the intention of focusing Trump’s attention, and at some point felt comfortable enough to start lying, confident in being dealt a Get Out of Jail Free card?

  11. mattbernius says:

    An provocative take on this news:

    The summary of the author’s take — through these public filings and other prosecutorial efforts, core contents of the Mueller report become public regardless of any decision made by the acting AG.

  12. Jen says:

    @mattbernius: Empty Wheel had a similar thought:

    If this is accurate, Mueller is clearly operating at a far higher strategic level than the current White House occupant or any of his handlers.

  13. Mr. Prosser says:

    Check out this post by Marcy Wheeler. I think this is it. “But Mueller’s team appears to have no doubt that Manafort was lying to them. That means they didn’t really need his testimony, at all. It also means they had no need to keep secrets — they could keep giving Manafort the impression that he was pulling a fast one over the prosecutors, all while reporting misleading information to Trump that he could use to fill out his open book test. Which increases the likelihood that Trump just submitted sworn answers to those questions full of lies.”

  14. Mr. Prosser says:

    @Jen: Sorry Jen, didn’t see your post before I posted.

  15. CSK says:

    Trump went on a real Twitter rampage this morning; he called Mueller a “conflicted prosecutor gone rogue.”

  16. Daryl and his brother Darryl says:

    @Daryl and his brother Darryl:
    Now Corsi is also claiming to have a “Super-Secret Joint Defense Agreement” with Dennison.
    You’ll no doubt remember that Corsi is a founding member of both the Swift-Boat and Birther conspiracy theories. Apparently he has written a 60,000 word weblog about his experience with Mueller – as yet to be published.
    I find it hard to believe that Mueller didn’t have both of these guys wire-tapped…I’m betting if they shit, Muellerr knew what color it was. Dennison has good reason to be scared shitless…his ongoing criminal enterprise is going to land him in jail.

  17. Jay L Gischer says:

    When I first saw this news, my daughter and I tried to figure out how someone makes a decision to lie to the people you just made a plea bargain with. The best answer I have is that Manafort is 69 and he’s got away with this kind of crap his entire life, and he can’t change now, he just keeps doing the grifting.

    Of course, there’s another thing here that maybe Manafort and Corsi and Trump and whomever isn’t thinking about. They probably have a bunch of counterintelligence wiretaps, etc. that can’t be used as evidence, but provide a very solid guide as to what sorts of things happen. Honestly, they’d be remiss if they didn’t have agents of the Russian government in the US under surveillance. They’ve had that all along, it’s their ace in the hole. And it’s the big difference between what’s going on now, and what they’ve had to deal with – municpal police forces and state attorneys general – before.

  18. MarkedMan says:

    Giuliani was especially ridiculous today. On the one hand he claims that Manafort was only a small part of the campaign (For the record: he was Trump’s frigging campaign manager!) and that anything that happened did so before or after Manafort was involved. On the other hand, when asked about Paulie’s trips to see Assange, Giuliani immediately responded “Fake News!” So which is it Rudy: Manafort was a bit player who was barely connected to the campaign, or he was so connected that you can immediately know that he wasn’t Ecuadorean embassy?

  19. mattbernius says:


    If this is accurate, Mueller is clearly operating at a far higher strategic level than the current White House occupant or any of his handlers.

    FWIW, our own HarvardLaw92 (who appears to know a number of these people closely) has been saying this for at least a year.

  20. Tyrell says:

    Who rides herd over Mueller and reins him in?

  21. JohnSF says:

    The main problem Mueller has, which has been quite plain for some time, is getting admissible evidence for what is already known.
    For heavens sake, Manafort visits Assange in London. Assange can’t sneeze without blowing out a bank of speakers in Cheltenham. What are these idiots thinking?

    I have some guesses:
    1) FSB/GRU have gotten sloppy; absolute thug power on home turf, and the UK not looking too hard at the oligarch war in London, can make you overconfident.

    2) They were counting on high level political/financial cover in London (e.g. the unbarking dog of Met lack of interest in Farage and Banks et al) forgetting that at lower levels routine 5I and FinInt sharing between US and UK agencies is uninterrupted.

    3) Failed to realise Assange has no out: absent all else High Court judges tend to sense of humour failure re. bail absconding.
    UK political leverage vs an annoyed judiciary? Overriding judicial power could be very iffy for any govt. let alone in current UK political situation.
    Trump pardons Assange? Nuclear meltdown in Congress.

    With testimony Mueller can get from Cohen, Weisselberg, Fin Cen records, Deutche Bank subpoenas, Manafort, etc etc to get justiciable evidence on what intel sources know, the Trump Org is toast.

    Why does anyone think that when Steele looked at TrumpOrg he started yelling at the FBI?

    I’m reluctant to disagree with Mike Reynolds, but I doubt Trump directly owned by FSB: IMHO he was too bloody vain stupid to know he was owned.
    BUT it’s plain to anybody who looks that TrumpOrg has been up to it’s elbows in dirty money for decades. And TrumpOrg/family is full of stupid wannabe Wise Guys who would fall headfirst into an FSB/GRU op. via existing mafiya connections thinking they were big time players. (DonJr, Kushner etc etc)

    P.S. re. London connection: wonder who rattled Trump’s cage re. Brexit. Anyone really think he came up with this UK/USA/EU trade deal stuff off his own bat?
    I trust the All Seeing Eye is looking at the transatlantic connections of ERG/55 Tufton Street/US admin insiders. And pray that their political cover gets burnt away.

    I live in hope of an almighty turning over of rocks and stomping of hobnailed boots before this saga is done.

  22. Mister Bluster says:

    @Tyrell:..Who rides herd over Mueller and reins him in?

    They all do! Rowdey Yates should be on that list too!

  23. mattbernius says:

    On a tangent, does anyone remember the days when our conservative commentators held up Jerome Corsi as a pinnacle of conservative intellectual rigor?

    Dude is making some really crazy ass court moves in terms of the amount of self incriminating material he’s releasing to the press:

  24. OzarkHillbilly says:

    @Tyrell: Rosenstein was the last word on that investigation. But now that the hopelessly compromised, hamstrung and none too bright Whitaker is supposedly “in charge” of the DOJ, maybe no one.

    Smooth move, trump.

  25. OzarkHillbilly says:

    @mattbernius: He’s building up his stupidi… I mean insanity defense.

  26. al Ameda says:


    Who rides herd over Mueller and reins him in?

    I’m sure you enjoyed Ken Starr’s 5 year investigation of all things Clinton?
    So why not this?

  27. dazedandconfused says:

    I wouldn’t be so quick to “rein” Mueller in.

    It may be that the people Mueller wants Manafort to rat out are Russian mobsters, not Trump, which would fit with Manafort’s behavior. It’s not so much his own carcass at risk, he’s 70 and can get protective custody, it would be his family’s. The mob would not hesitate threatening to kill them if he squeals. Witness protection is not an option for a public figure such as Manafort.

    The media in general suffers from an obsession with Trump, but I got a hunch that to Mueller a Trump is merely ridiculous. Trump’s just a rich old con man. Small game. Russian mobsters? Killers. Big game. Manafort was laundering Russian mob money, not Trumps.

  28. Tyrell says:

    @dazedandconfused: “The media suffers an obsession with Trump”
    You got that straight. On some networks it’s 24/7, with commentators hollering at each other and guests, negativity, and ignoring other important stories. The people out here in the hinterland don’t care about that junk. People are interested in technology, self help, home improvement, new cars, health, education, and space exploration. I have gone to alternative sources that are positive, educational, and uplifting.
    How about it, Mr. O’Donnell: could you manage to talk about the recent Mars landing or the cold weather we are having? How about some Christmas news? Would it hurt to just go one night and not mention Trump? What about it, Lawrence?
    “Mueller who?”