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Manafort Motion to Dismiss 3.0

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Posted on March 16 2018

Manafort files a motion to dismiss

and I snort laughed, uncontrollably…

In 3 different late night Wednesday filings, Manafort’s Attorney Kevin Downing federal judge to throw out five criminal charges against him.

Here are a few of the highlights of Manafort’s First Motion to Dismiss:

  • “The regulations do not allow for such an expansive appointment,”
  • “power to investigate a specifically identified matter and anything that arises in the course of the investigation..”
  • “The original and superseding indictments do not focus in the slightest on alleged coordination between the Russian government or even Mr. Manafort’s brief involvement in the Trump Campaign”
  • “game of criminal-procedure whack-a-mole against a special counsel whose massive resources he cannot possibly hope to match.”

Manafort Motion to Dismiss 1 of 3

The fact that Manafort’s Attorney once again fails to acknowledge that the DOJ’s regulations were promulgated by the (now sunsetted) Special Counsel Act. Well it’s just sloppy and intellectually dishonest.

Link to 28 CFR 600 Special Counsel

28 CFR§600

General Powers of a Special Counsel

  • §600.1 Grounds for appointing a Special Counsel
  • §600.4 Jurisdiction.
  • § 600.6 Powers and authority.


One could argue that Manafort’s Motion to Strike Assest Forfeiture is a predictable move. Given the Susperseding Indictment lays down a solid argument, alleging that Manafort engaged in criminal activities, such as: Loan Fraud, Money Laundering, failure to register FARA

Meaning the Government argument is: the “money” Manafort used to buy various Real Estate were ill gotten, thereby arguing the Real Estate Manafort purchased should be forfeited. My guess is Manafort can see the writing on the wall and perhaps the Government plans to move foward to request the Court Order Manafort to be remanded. Again that’s my speculation, so please take that with a grain of salt.

  • “The court should order any restraint of property based upon the forfeiture allegation be rescinded and the property released,”

Link to Manafort’s Motion to Strike Assest Forfeiture here

Manafort MTD Count 2 and Strike Forfeiture Allegations


Now we move to Manafort’s Motion to Dismiss Count Two. Citing multiplicitous counts. What I found intriguing is at no time does Manafort acknowledge the he “by and through” refused to waive venue.

And finally according to the United States Attorneys Manual, specifically sections 819 & 919 it appears that  SCO Mueller’s team followed USAM 919 Multiplicity

  • “They focus instead on Mr. Manafort’s consulting work in Ukraine, which ended in 2014, years before the Trump campaign even launched; on bank accounts and tax filings from 2006 to 2014, which have no connection to the Russian government and again predate the Trump campaign by years..”
  • ”Mr. Manafort’s personal expenditures from 2006 to 2014 which likewise have no connection to the Russian government and predate the Trump campaign and Manafort’s brief involvement in by years.”
  • “It contains no allegations of coordination between individuals associated with President Trump’s campaign and the Russian government, the very reason for the Office of Special Counsel’s existence,”

Link to Manafort’s second Motion to Dismiss below:

Manafort’s MTD one of two multiplicitous counts



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