Paul Manafort leaves the U.S. District Court for the District of Columbia after a status conference on Nov. 2, 2017.  (Photo: Diego M. Radzinschi / ALM)

Paul Manafort should receive a “less stringent” sentence in Washington, D.C., his attorneys told a federal judge Monday in a memo that painted the former Trump campaign chairman as far from the “hardened criminal” that federal prosecutors portrayed.

In a sentencing memo filed Monday, Manafort’s attorneys told Judge Amy Berman Jackson of the U.S. District Court for the District of Columbia that Manafort should serve no more than 10 years for his conduct. They urged the court to “exercise its broad discretion” to avoid banishing him to what will likely be a lifetime in prison.

“Mr. Manafort has been punished substantially, including the forfeiture of most of his assets,” his attorneys wrote. “In light of his age and health concerns, a significant additional period of incarceration will likely amount to a life sentence for a first time offender.”

Manafort is set to be sentenced March 13 in Washington in what will be the second in a pair of hearings that will determine the longtime lobbyist’s fate. Jackson will sentence him for two counts of conspiracy that he pleaded guilty to in September, one count of conspiracy against the U.S. and the other related to a witness-tampering effort.

Manafort faces a maximum of 10 years combined for those two counts, his attorneys said. Still, at 69 years old, Manafort faces the possibility of a lifetime in prison. He’s set to be sentenced for separate crimes in Alexandria, Virginia, where the government told a judge they support a sentence of 19.5 years to 24.5 years.

In their 47-page memo Monday, Manafort’s lawyers argued that his sentences in D.C. and Virginia should run concurrently, because the underlying conduct in both criminal cases was related.

In seeking a lighter sentence, Manafort’s attorneys wrote that their client accepted responsibility for his crimes in Washington, D.C. But they also painted him as someone who was unfairly prosecuted, arguing he was charged for crimes that weren’t central to special counsel Robert Mueller III’s investigation into possible links between the Kremlin and the Trump campaign in the 2016 U.S. election.

They also described how some of Manafort’s charges stemmed from the failure to notify the Justice Department about his foreign lobbying work for Ukraine, which they admitted was a violation of the Foreign Agents Registration Act. But they pointed to how rarely the Justice Department enforced the law before Manafort and described how his initial failure to file paperwork, which would have ordinarily been handled “administratively,” evolved into a criminal case with “a magnitude of harshness previously unknown in the enforcement of FARA.”

“[I]t is fair to say that, but for the appointment of the Special Counsel and his Office’s decision to pursue Mr. Manafort for a rarely prosecuted FARA violation, Mr. Manafort would not have been indicted in the District of Columbia,” they wrote.

Manafort is represented by Kevin Downing, Thomas Zehnle, and Epstein Becker & Green attorney Richard Westling.

Special counsel prosecutors told Jackson last week that Manafort should serve a lengthy prison term for the “bold” criminal actions he orchestrated for more than a decade. Prosecutors said they did not support a downward departure from an estimated sentencing guideline range of 17.5 years to 22 years in prison. The government did not present a single mitigating factor.

Manafort also will be sentenced on March 8 in Alexandria, Virginia, for financial fraud convictions. In that case, the government has supported a sentence of 19.5 years to 24.5 years in prison. The government on Saturday did not take a position on whether the sentence Jackson imposes on March 13 should run on top of or concurrent with the Virginia sentence.

Under a September plea deal, prosecutors had agreed to recommend that Manafort serve his two sentences concurrently. But Jackson freed prosecutors from that obligation when she found that prosecutors had proven “by a preponderance of the evidence” that Manafort intentionally lied to federal authorities on a variety of matters, when he was required to cooperate.

Prosecutors said they will make a recommendation on whether the sentence should be consecutive or concurrent to charges he was convicted on in Virginia, once that sentence is imposed.

Read the sentencing memo here:

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