1. discussed or may have discussed a Ukraine peace plan with Mr. Kilimnik on more than one occasion); id. at 6 (After being told that Mr. Kilimnik had traveled to Madrid on the same day that Mr. Manafort was in Madrid, Mr. Manafort acknowledged that he and Mr. Kilimnik met while they were both in Madrid)).
2. In fact, during a proffer meeting held with the Special Counsel on September 11, 2018, Mr. Manafort explained to the Government attorneys and investigators that he would have given the Ukrainian peace plan more thought, had the issue not been raised during the period he was engaged with work related to the presidential Case 1:17-cr-00201-ABJ Document 471 Filed 01/08/19 Page 5 of 10 6 campaign. Issues and communications related to Ukrainian political events simply were not at the forefront of Mr. Manaforts mind during the period at issue and it is not surprising at all that Mr. Manafort was unable to recall specific details prior to having his recollection refreshed. The same is true with regard to the Governments allegation that Mr. Manafort lied about sharing polling data with Mr. Kilimnik related to the 2016 presidential campaign. (See Doc. 460 at 6). (See, e.g., Doc. 460 at 5 (After being shown documents, Mr. Manafort conceded that he
3. The Government has indicated that Mr. Manaforts statements about this payment are inconsistent with those of others, but the defense has not received any witness statements to support this contention.
4. The first alleged misstatement identified in the Special Counsels submission (regarding a text exchange on May 26, 2018) related to a text message from a third-party asking permission to use Mr. Manaforts name as an introduction in the event the third-party met the President. This does not constitute outreach by Mr. Manafort to the President. The second example identified by the Special Counsel is hearsay purportedly offered by an undisclosed third party and the defense has not been provided with the statement (or any witness statements that form the basis for alleging intentional falsehoods).