Special counsel Robert Mueller’s sentencing memo in the second criminal case against former Trump campaign manager Paul Manafort was due at midnight. But by Saturday morning, the anticipated document still had not been made public.
Speculation swirled Saturday that the document had been filed under seal, with suggested redactions of sensitive information that Jackson will need to approve before releasing the document.
The memo would outline Mueller’s recommendations for punishment to Judge Amy Berman Jackson, who has been overseeing the case in Washington, D.C. Manafort, 69, accepted a plea deal in the Washington, D.C., case in September, admitting to one count of conspiracy against the U.S. and one count of obstructing justice for his work illegally lobbying on behalf of Ukrainian interests.
He had earlier been convicted in Virginia in August on eight counts, including bank fraud, tax fraud, and failure to disclose a foreign bank account.
But Manafort’s deal had included the stipulation he cooperate with the special counsel, who is looking into Russian meddling in the 2016 presidential election. And Jackson ruled earlier this month that Manafort had lied to federal prosecutors, breaching his plea deal and opening him up to a long sentence.
Mueller is already facing 19 to 24 years in prison in the Virginia case, which Mueller requested last week. Sentencing in the Virginia case is scheduled for March 8; the D.C. case, March 13.

