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Tierney Sneed

Tierney Sneed is a reporter for Talking Points Memo. She previously worked for U.S. News and World Report. She grew up in Florida and attended Georgetown University.

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Special counsel Robert Mueller announced Friday a new grand jury indictment of former Trump campaign chairman Paul Manafort and his longtime Russian business deputy for alleged witness tampering in the case that was already pending against Manafort.

Konstantin Kilimnik, Manafort’s business deputy, has been alluded to in previous Mueller court filings, which have claimed that he’s had ties to a Russian intelligence service.

The special counsel on Friday brought charges of obstruction of justice and conspiracy to obstruct justice against the two men.

“From in or about and between February 23, 2018, and April 2018, both dates being approximate and inclusive, within the District of Columbia and elsewhere, the defendants Paul Manafort, and Konstantin Kilimnik, knowingly and intentionally conspired to corruptly persuade another person, to wit: Persons D1 and D2, with intent to influence, delay, and, prevent the testimony of any person in an official proceeding,” Mueller said in the filing.

Manafort previously was facing charges brought in D.C, that included money laundering, failure to disclose foreign lobbying and false statements. Those charges remain unchanged in the new indictment.

Mueller has also brought a case against Manafort in Virginia, where the charges include bank fraud and tax fraud.

Manafort has pleaded not guilty in both cases.

Mueller first made the witness tampering allegations against Manafort on Monday evening, in court filings seeking that his current release on house arrest be revised or revoked. It appears Mueller was able to quickly convince a grand jury to approve the charges, and prosecutors have put on a full court press to pressure Manafort to cooperate on the probe.

Before Friday’s new charges, U.S. District Judge Amy Berman Jackson had scheduled a hearing for next Friday on the bail revocation, and it is possible that Manafort that be sent directly from the courthouse to jail, due to the allegations.

According to Mueller, Manafort and Kilimnik — who up until Friday’s new indictment, was referred to as “Person A” in the special counsel’s court filings — sought to make contact with two former business associates who were involved in Manafort’s Ukraine lobbying work. The two former associates, according to Mueller, were in charge of coordinating a group of ex-European politicians known as the “Hapsburg group,” who sought to promote Ukraine’s Party of Regions in Europe and the U.S.

Manafort’s and Kilimnik’s alleged outreached involved both phone calls and texts which started in February, when Mueller unveiled new allegations against Manafort having to do with the “Hapsburg group.”

Defense attorneys unconnected to the case told TPM earlier this week that Monday’s bail revocation filing, which included a log of the alleged texts and calls, was especially persuasive.

“You could put this evidence in front of a grand jury and they would indict him in a nano second,”said Nick Akerman, a defense attorney and former Watergate prosecutor. “If you had these two witness and these documents, you put them before a trial jury, they’d convict them in two seconds. Its really a pretty overwhelming case.”

Kilimnik made his first appearance in Mueller’s court filings as “Person A,” when Mueller alleged last year that Manafort had sought to ghost-write an op-ed for a Ukraine news outlet, in violation of judge’s gag order on the case. Emails obtained by TPM showed Kilimnik correspondence with a former Ukrainian politician who claimed to be the op-ed author, in which Kilimnik informed him that he was sending a draft to Manafort to look over.

Other court documents filed by Mueller have described “Person A” as having had “ties to a Russian intelligence service and had such ties in 2016.”

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Multiple witnesses appeared in front of a House Judiciary subcommittee hearing Friday to testify in favor or against the addition of a citizenship question to the 2020 census — a Trump administration move that is roiling the civil rights community and prompting numerous lawsuits.

But the Republican lawmakers who showed up to participate in the hearing seemed most interested in speaking to Alabama Attorney General Steve Marshall, who is bringing a lawsuit seeking to alter how the U.S. congressional map is drawn to diminish the political power of immigrant-friendly states.

His lawsuit is parallel to the push for a census citizenship question, but if successful, could have just as drastic of an effect, if not more. Whereas the Trump administration has claimed it needs census citizenship data for Voting Rights Act enforcement (a claim viewed skeptically by voting rights activists), the Alabama lawsuit explicitly seeks to exclude undocumented immigrants from how U.S. congressional seats are apportioned.

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Both Eric Murphy and Chad Readler have defended Ohio’s voting restrictions in cases in front of the Sixth U.S. Circuit Court of Appeals. Now, Murphy, the state’s solicitor general, and Readler, who currently works at the Justice Department, will both have a chance to sit on that appeals court, thanks to nominations announced by the White House Thursday.

Murphy, last fall, argued for Ohio in front of the Supreme Court, in a case challenging the state’s voter purge system. The system allows election officials to remove voters from the rolls if they sit out two federal elections in a row and do not respond to subsequent notifications from the state. Voting rights advocates say it’s disenfranchising eligible voters.

The Sixth Circuit ruled against Ohio in 2016.  The Supreme Court has not handed down its decision in the case yet.

Murphy also defended Ohio when it was sued for its 2014 cutbacks to early voting, which eliminated the state’s “golden week,” when voters could register and vote at the same time. The appeals court ultimately ruled in favor of Ohio, overturning a lower court’s decision.

Readler, meanwhile, worked on Ohio election law cases when he was an attorney for Jones Day (where Murphy also worked for some time). He was involved in writing Ohio’s legal briefs supporting a law that allowed election officials to throw out the ballots of absentee and provisional voters if the addresses and birthdates they fill out on the ballot forms didn’t perfectly match what’s in the state’s records.

Readler also represented the Trump campaign in election-related cases, including a lawsuit bought by Ohio Democrats alleging Trump’s calls for vigilante poll watchers amounted to voter intimidation.

Since joining the Trump administration in January 2017, Readler has led the DOJ’s Civil Division as its acting head. Trump has since nominated Attorney General Jeff Sessions’ chief-of-staff, Jody Hunt, to take over the division. Hunt’s nomination awaits Senate confirmation.

Progressive groups are already signaling that they’ll oppose Readler’s and Murphy’s nominations.

“These individuals would pose serious threats to the rights and liberties of people in the Sixth Circuit if they were to become federal judges,” Nan Aron, the president of Alliance for Justice, said in a statement that pointed specifically to both nominees’ records on voting rights, among other things.

Democrats won’t likely have any tools to stop them from bring confirmed. Senate Judiciary Chairman Chuck Grassley (R-IA) has said he will no longer honor the committee’s custom on blue slips — in which nominees only move forward in committee if both home state senators turn in blue slips approving of their advancement — on appeals court nominees, unless he believes that the White House did not confer with the home state senators in choosing the appointees.

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On Thursday, I wrote about what comes next for Paul Manafort, now that special counsel Robert Mueller has alleged he engaged in witness tampering. It seems possible — and maybe likely — that the U.S. District Judge Amy Berman Jackson will order that he be placed in detention after holding a hearing next Friday.

While reporting this piece, I spoke to a number of white collar-defense attorneys and former prosecutor-types. One, Harry Sandick — a defense attorney and former Assistant U.S. Attorney in Manhattan — laid out how these hearings usually go.

“Many bail hearings have a back-and-forth quality, almost like a tennis match,” he explained. “Each lawyer argues and responds, and counter-responds, back and forth and back and forth, until the judge says ‘I’ve heard enough.'”

Manafort may learn his fate pretty quickly, Sandick said. “Sometimes a judge proceeds immediately to a decision. Given that this is a high-profile case, it seems possible that she would take a brief adjournment, and then come back on the bench to issue an opinion.

“There is some possibility that she won’t do anything on Friday, and she’ll keep it open until after the weekend, but most bail decisions come pretty quickly after argument, in part because if someone should be in pretrial detention, that should start immediately.”

Whatever happens, I’ll be at the courthouse next Friday to report on it.

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Former Trump campaign chairman Paul Manafort may have only one more week to wear his famously fancy Italian suits.

Manafort will be appearing in front of a federal judge in a D.C. courthouse for a June 15 hearing on allegations that he engaged in witness tampering while awaiting trial in special counsel Robert Mueller’s investigation. It is possible, and even likely, that U.S. District Judge Amy Berman Jackson will order Manafort — who has been under house arrest since October — into immediate detention until his trial, which is currently scheduled for Sept. 17.

“I don’t see how he leaves the courthouse and doesn’t go directly to jail,” Nick Akerman, a defense attorney and former Watergate prosecutor, told TPM.

[ Read a reporter’s notebook from Tierney Sneed on how Manafort’s bail hearing might go » ]

Though his trial doesn’t start for several weeks — with sentencing, if convicted, even farther in the future — the Trump campaign chairman who had advised other GOP presidential campaigns may be headed to jail much sooner. It would be a remarkable fall for a political operative who was once dubbed the leader of “the torturers’ lobby,” given the millions Manafort made representing foreign dictators. It could also dramatically ratchet up the pressure on Manafort to cooperate with the Mueller probe, which could pose new legal threats to President Trump and his associates.

“Unless he comes up with some good arguments that completely undercut what I see right now, in the very strong government motion, I think she’s going to put him in,” said Patrick Cotter, a former federal prosecutor and longtime white-collar defense attorney.

Mueller alleges Manafort attempted to reach out to former two associates involved in his Ukraine lobbying effort, from which many of the charges against him stem. Manafort and his business partner Konstantin Kilimnik (only identified as “Person A” in the filings) allegedly texted and called the associates starting in February, after new charges against Manafort were unveiled, the court documents said. According to the filings, Kilimnik told one associate in a text that Manafort wanted to “give him a quick summary that he says to everybody (which is true) that our friends never lobbied in the US, and the purpose of the program was EU.” Mueller also filed emails and memos that allegedly show the associates had, in fact, partaken in lobbying activities within the U.S.

The papers, I think, read persuasively,” said white collar defense attorney and former prosecutor Harry Sandick, who added that the “biggest single factor” in whether Manafort goes to jail next week “is the views of the judge who makes the decision.”

It’s a very discretionary decision. There is no legal rule that compels the defendant to be detained or not detained,” he said.

Manafort has until Friday morning to file a response to Mueller’s allegations. He may try to present evidence that rebuts Mueller’s narrative and he could put forward a defense based on the law, arguing that his alleged behavior does not require that he be sent to jail.

At next week’s hearing, the government is not required to present its evidence through witness testimony the way it must at a trial. So the hearing could be focused just on what’s in the court filings — though the judge requested that the FBI agent who filed a declaration supporting Mueller’s allegations, as well as any other witnesses either side wants to call, should be ready to testify.

“The only possible witness that Manafort can bring forward is himself. And he would be absolutely wacko to take the stand and waive his Fifth Amendment privilege here,” Akerman said.

The witness tampering allegations relate to the charges Mueller brought that Manafort failed to disclose foreign lobbying. He also has been charged with an assortment of financial crimes, both in D.C. and in Virginia, arising from the Ukraine lobbying work, which predated President Trump’s campaign. He has pleaded not guilty in both cases. The Virginia trial is slated for the end of July.

Manafort’s spokesman Jason Maloni declined to comment for this story, but in a statement after Mueller’s witness tampering allegations, said Manafort was “innocent” and that the latest allegations would not change his defense.

For Manafort’s bail to be revoked, Mueller must only convince a judge that there is probable cause — a notably lower standard than beyond reasonable doubt — to believe that Manafort committed a crime, and that there is no combination of conditions of release that will prevent Manafort from fleeing, posing a danger to the community, or violating his bail.

“The government has clearly established its burden of at least probable cause,” Ackerman said.

Still, in bail hearings, like in sentencing, judges are left with broad discretion, and Jackson could choose to impose new restrictions on Manafort’s house arrest conditions, or just give him a heavy tongue lashing.

Manafort got a pass, albeit with a scolding from the judge, when he previously violated the court’s gag order on the case. On the other hand, Jackson gave a lawyer who pleaded guilty to misleading Mueller’s investigators a month in prison, even though the prosecutors weren’t requesting any jail time.

Most judges take violation of bond conditions as a personal betrayal,” Cotter said.

Jackson’s decision to push the hearing off until next week could be a sign that she does not think Manafort poses a danger to the public, or it could mean that she wants to give Manafort plenty of time to respond and for her to consider his arguments “to create a record of fairness as she decides to put him in,” Sandick said.

“Certainly his lawyers are telling him today, ‘Look Paul, she likely is going to rule a week from Friday, so you need to get your affairs in order now. You need to prepare for going in. Now we are going to fight to prevent that, but you’ve got to prepare for that,’” Cotter said.

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Newly revealed details about how White House Counsel Don McGahn remembered his late January 2017 meetings with Sally Yates, then the acting Attorney General, confirmed much of Yates’ own account of the meetings. Yates has testified that she informed McGahn of false statements given by then-National Security Advisor Mike Flynn to Vice President Mike Pence about Flynn’s conversations with a Russian official.

But the account laid out by McGahn in a memo that partially became public Saturday differs from Yates’ testimony, given to the Senate Judiciary committee in early May 2017, in a few key areas. Those differences point to the major questions still lingering in Special Counsel Robert Mueller’s investigation into Russian election meddling, and particularly his probe into whether President Trump obstructed justice.

McGahn and Yates disagree on whether Yates signaled to McGhan that Flynn gave the FBI, as well as Pence, a false account of his phone calls with Russian ambassador Sergey Kislyak during the presidential transition. In December, Flynn pleaded guilty to lying to the FBI in a January 24, 2017 interview about whether the topic of Russian sanctions came up.

The question matters because what Trump knew by February 2017 about whether Flynn lied to the FBI could help explain why Trump allegedly asked then-FBI director James Comey to go easy on Flynn before firing him in May. If Trump did make that request, it could be evidence of obstruction of justice.

McGahn’s account of his two January meetings with Yates comes in the form of a memo he wrote about two weeks after the meetings, which is quoted repeatedly by Trump’s personal attorneys in their recently leaked January 2018 letter to Mueller. In the letter, Trump’s attorneys argued that the White House concluded from McGahn’s discussion with Yates that Flynn was not under FBI investigation. Yates’ testimony casts doubt on that assumption, and it’s not even fully backed up by the portions of the McGahn memo that Trump’s attorneys quote.

In many places, McGahn’s memo lines up with Yates’ testimony. But some of the details don’t match, or at the very least, define the holes in the story. Because the Trump attorneys’ letter only quotes selectively from McGahn’s memo — and the memo hasn’t been released in full — it’s hard to know which gaps between the two accounts are outright contradictions, or just products of what the lawyers left out about McGahn’s memorialization of the meeting.

Neither Yates nor the White House responded to TPM’s questions about the discrepancies. The February 15 McGahn memo has been turned over to Mueller’s investigation, according to the Trump attorneys’ letter.

January 26: The First Yates-McGahn Meeting

According to McGahn’s memo, Yates told him at the meeting, which took place in a McGahn’s office at the White House, “that Flynn may have made false representations to others in the Administration regarding the content of the calls.” Yates also explained why that made him vulnerable to blackmail, according to the memo.

Yates’ testimony backed up that recollection. But the two accounts differ in a major way. McGahn’s memo says that “Yates claimed that Flynn’s statements to the FBI were similar to those she understood he had made to Spicer and the Vice President.” Yates, meanwhile told Congress that, when she informed McGahn that Flynn had been interviewed by the FBI, she declined to answer McGahn’s question about how Flynn did in the FBI’s questioning.

The question of how the White House knew that Flynn had misled FBI agents in the same way he misled Pence came up previously, when Trump in a December 2017 tweet claimed he fired Flynn for both his lies to Pence and to the FBI. Up until that tweet, the White House’s line was that Flynn was fired for misleading just Pence. If Trump knew in early 2017 that Flynn also lied to the FBI, that could be evidence that he obstructed justice when he allegedly urged Comey to go easy on Flynn.

Later January 26: McGahn Briefs Trump, Priebus, and “Other Advisors” About Yates’ Flynn Claims

After his meeting with Yates, McGahn briefed Trump, then-chief of staff Reince Priebus and “other advisors” about Yates’ Flynn claims, according to the Trump attorneys’ letter.

Among the concerns expressed during the briefing “was a recognition by McGahn that it was unclear from the meeting with Yates whether an action could be taken without jeopardizing an ongoing investigation,” McGahn’s memo said. “President Trump asked McGahn to further look into the issue as well as finding out more about the calls.”

According to her testimony, Yates had told McGahn at the first meeting that it was up to the White House what to do about Flynn. It’s not clear if she told him anything more about how such action would affect an ongoing probe.

McGahn would go on to request a second meeting with Yates.

Yates testified that McGahn did not indicate to her during the second meeting that he had discussed their first Flynn meeting with anyone else. A February 14 2017 statement from then-White House Press Secretary Sean Spicer recounted McGahn’s briefing of Trump and “a small group of senior advisors.”

January 27: Second Yates-McGahn meeting

Yates and McGahn both said that McGahn had raised concerns about whether the White House taking action against Flynn would affect an ongoing investigation.

“We told him, both the senior career official and I, that he should not be concerned with it, that General Flynn had been interviewed, that their action would not interfere with any investigation and in fact, I remember specifically saying, you know it wouldn’t really be fair of us to tell you this and then expect you to sit on your hands,” Yates testified. In addition to a DOJ lawyer that accompanied Yates, a White House associate working with McGahn also was at the meeting.

McGahn’s memo, likewise, said that Yates indicated “that the DOJ would not object to the White House taking action against Flynn,” but also recounted that Yates refused to confirm or deny an investigation.

The McGahn memo revealed for the first time his recollection that Yates “indicated that the DOJ would not object to the White House disclosing how the DOJ obtained the information relayed to the White House regarding Flynn’s calls with Ambassador Kislyak.”

The New York Times interpreted that to be a reference to the wiretap on Kislyak that picked up his conversations with Flynn.

Trump’s attorneys, in their letter, argued that Yates’ green-lighting of such a disclosure helped the White House conclude that there was no active investigation into Flynn — and thus Trump couldn’t have been obstructing it with his request to Comey.

But when Yates, in her testimony, went through the topics that had come up in her meeting with McGahn, she didn’t mention giving him permission to disclose the surveillance.

“The first topic in the second meeting was essentially why does it matter to DOJ if one White House official lies to another. The second topic related to the applicability of criminal statutes and the likelihood that the Department of Justice would pursue a criminal case,” she testified. “The third topic was his concern that their taking action might interfere with an investigation of Mr. Flynn. And the fourth topic was his request to see the underlying evidence.”

Yates testified that she told McGahn it was likely he’d be able to look at the underlying evidence, but that she wanted to work it out with the FBI first over the weekend. That Monday morning, she called McGahn to let him know he could come over to the Justice Department. Yates was fired by Trump later that night over her refusal to defend his travel ban.

Conversations With Flynn After the Yates Meetings

The Trump attorneys’ letter doesn’t say whether McGahn continued to seek the underlying evidence against Flynn. But it documents other conversations White House officials had with Flynn about Yates’ claims.

McGahn was in a February 8 meeting with Priebus, Flynn and another White House official where Priebus “asked Flynn whether Flynn spoke about sanctions on his call with Ambassador Kislyak,” according to the letter. Flynn said he wasn’t sure and didn’t remember doing so. Asked about the FBI interview, Flynn told Preibus “that FBI agents met with him to inform him that their investigation was over.”

Flynn would claim on another phone call with McGahn on February 10 that “the FBI told him they were closing it out,” according to the letter.

That day, McGahn and Preibus would tell Trump he had to let Flynn go, and by February 13, his resignation letter was handed in. McGahn wrote the memo two days later, the day after Trump had dinner with Comey and allegedly asked him for his loyalty.

 

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Sen. Lindsay Graham (R-SC) wants to know if Deputy Attorney General Rod Rosenstein — who’s overseeing special counsel Robert Mueller’s investigation — is serving as a witness in the probe, and if so, whether he should recuse himself from overseeing it.

Graham’s queries came in a letter to Rosenstein dated May 31. Graham told Fox News he sent it after a New York Times report on a memo then-FBI Deputy Director Andrew McCabe wrote about Rosenstein’s involvement in former FBI Director Jim Comey’s firing. McCabe has turned over his memo to Mueller, who is investigating Comey’s termination as part of an obstruction of justice probe.

“Do you consider yourself a potential witness in the Mueller investigation regarding the firing of Director Comey by President Trump?” Graham’s letter asks Rosenstein. “If not, why not?

“If so, should you recuse yourself from further interactions with and oversight of the Mueller investigation?”

Graham, on Fox News, pointed to the memo that Rosenstein wrote on Comey that Trump used as justification for firing Comey. (Rosenstein has said in Congressional testimony that his memo — which focused on Comey’s handling of the Hillary Clinton email probe — was “not a statement of reasons to justify a for-cause termination,” but has defended his at-times scathing assessment of Comey’s actions.)

“You can’t oversee an investigation where you’re going to be a witness in that investigation,” Graham said, later adding that he was also skeptical Rosenstein could oversee any investigation into a surveillance warrant that the FBI sought on an ex-Trump campaign advisor, since Rosenstein signed off on some of the warrant applications.

Graham reiterated his belief the Mueller should do his investigaton without interference.

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A spokesman for Paul Manafort appeared to respond Tuesday to allegations made by special counsel Robert Mueller that the former Trump campaign chairman had engaged in witness tampering while facing charges in two criminal cases.

“Mr. Manafort is innocent and nothing about this latest allegation changes our defense,” spokesman Jason Maloni said in a statement Tuesday. “We will do our talking in court.”

U.S. District Judge Amy Berman Jackson, who’s overseeing the case against Manafort in D.C., gave Manafort’s lawyers until Friday to file a response to Mueller’s allegations, which first surfaced Monday evening in court documents. She also scheduled a hearing on the matter for the morning of Friday, June 15.

Prosecutors are asking the judge to throw Manafort in jail while he awaits trial.

Mueller in filings Monday night said that Manafort had sought to reach out to two former business associates who allegedly helped coordinate a group of former European leaders said to be involved in Manafort’s lobbying for Ukraine. According to the filings, Manafort tried calling and texting one of  the associates directly, while  his longtime business partner Konstantin Kilimnik — dubbed by Mueller as “Person A” — reached out to the both associates in encrypted texts where he said he was trying to deliver a message from his “friend P.”

The texts and calls started after Mueller revealed a new set of charges that included the allegations about the group of ex-European leaders, known in the court documents as the Hapsburg group.

“Basically P wants to give him a quick summary that he says to everybody (which is true) that our friends never lobbied in the US, and the purpose of the program was EU,” one of the Kilimnik texts said, according to Mueller’s court filings. The filings also included emails that allegedly showed the Hapsburg group’s involvement in lobbying efforts in the U.S.

Manafort has pleaded not guilty to the charges, that have included money laundering and failure to disclose foreign lobbying, that have been brought against him.

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Special counsel Robert Mueller in court filings Monday evening accused former Trump campaign chairman Paul Manafort of witness tampering and asked for a judge to revoke his current house arrest and send him to jail.

Prosecutors alleged that Manafort sought to shape the testimony of witnesses beginning earlier this year. They claim that a person they dub as Person A reached out over encrypted texts to two former business associates of Manafort who were involved in his Ukraine lobbying work, according to the filings. The texts started in late February, just after Mueller unsealed a new indictment against Manafort in Washington, D.C., the prosecutors said.

Manafort has been charged in D.C. with money laundering, false statements and failure to disclose foreign lobbying. He also faces charges that include bank fraud and tax fraud in Virginia. He’s pleaded not guilty in both cases.

The charges that were revealed in late February included allegations that Manafort used a group of former European leaders — called the “Hapsburg” group — to secretly promote Ukraine’s Party of Regions in the United States. According to Monday’s filing, Person A sought to communicate with two former Manafort associates who worked  at a PR firm that acted as a intermediary between him and the  “Hapsburg” group.

Person A told one associate that Manafort wanted to get in touch with the second associate to “give him a quick summary that he says to everybody (which
is true) that our friends never lobbied in the US, and the purpose of the program was EU,” according to the texts quoted in the filings.

Manafort himself also attempted to reach one of the associates via texts and phone calls himself, according to a log of the alleged communications provided in the filings. One of those texts was a link to February 25 Business Insider story about how European politicians believed to be members of the Hapsburg group were reacting to Mueller’s allegations.

Mueller on Monday night filed a number of documents — emails and memos — he says shows that the Hapsburg group was in fact in engaged in lobbying in the United States. They include emails about connecting the European politicians with U.S. Senators, and placing op-eds in American news outlets.

Prosecutors are asking the judge, U.S. District Judge Amy Berman Jackson, to rethink Manafort’s current placement in home confinement, and suggested that he may need to be put in jail.  The move comes after months of back and forth between prosecutors and Manafort over the terms of his release, whether he’s posted sufficient bond for his bail, where he can live and travel, and other related restrictions.

“Manafort’s obstructive conduct—carried out at a time when he was seeking relief from his current conditions of release—instills little confidence that restrictions short of detention will assure Manafort’s compliance with the Court’s orders and prevent him from committing further crimes,” Mueller said.

Read the Mueller request that Manafort’s house arrest be revoked, as well as the affidavit filed by an FBI agent about the communications below. A log of the alleged communications from Manafort and Person A to the two business associates are also below:

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President Trump’s insistent, baseless claims that millions of people voted illegally in 2016 appear to have convinced a significant number of Republicans. Forty-eight percent of Republicans said they believed 3 to 5 million people voted illegally, according to a new HuffPost/YouGov poll released last Sunday. That’s the number Trump once touted without a shred of evidence. Only 17 percent of Republicans said that they did not believe that 3 to 5 million voted illegally.

The poll also found that Republicans — by a 56-point margin — said widespread voter fraud was a bigger problem than legitimate voters being prevented from voting. Democrats, meanwhile, said by a 23-point margin voter suppression was a bigger issue.

Meanwhile, New Hampshire’s Secretary of State and Attorney General’s office both noted this week how few actual cases of voting fraud occurred in the state. New Hampshire Associate Attorney General Anne Edwards, for example, said this week that it had uncovered only five cases of wrongfully cast votes since Sept. 2016 — one of which was the fault of an election official who gave a student incorrect information about where he should be voting.

Nonetheless, New Hampshire Republicans are pushing a measure that will make it harder for students to vote in the state. The GOP-led legislature has passed the bill, but Gov. Chris Sununu (R) has asked the state Supreme Court to review the legislation before he signs it.

The push in Maine to move to a ranked-choice voting system got another court ruling in its favor Tuesday, when a federal judge said that the state must use the system in the upcoming primary, in lawsuit brought by Republicans attempting to hold on to the old plurality-of-votes system.

The Trump administration is facing yet another lawsuit for its decision to add a citizenship question to the 2020 Census — this one filed in Maryland on Thursday.

Thursday also brought a decision by the 5th U.S. Court of Appeals in an ongoing case about whether or not Texas violated the National Voter Registration Act. The court granted Texas’s request and temporarily halted a lower-court decision requiring the state to fix its online DMV system so that Texans who are updating driver’s license info online are also given the opportunity to register to vote online. For now, Texas won’t have to make the fixes ordered by the lower court while the appeals court considers its appeal of the case.

Meanwhile, the Milwaukee Journal Sentinel noted last week that Wisconsin has been waiting for 16 months for a federal appeals court decision. The state had sued the ACLU to block it from using state records to contact voters who might have trouble getting voter ID. A state court version of the lawsuit has already been thrown out.

Eric Holder’s anti-gerrymandering group, National Democratic Redistricting Committee, made moves this week to pour $175,000 into two Wisconsin state special elections, as part of its effort to elect state-level Democrats who they say will draw fairer maps after the 2020 Census.

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