United States v. Manafort, No. 18-3037 (D.C. Cir. 2018)
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The DC Circuit affirmed a pretrial detention order that was issued after release was revoked because of Paul Manafort's alleged commission of new crimes of witness tampering while he was on release. The Government contended that Manafort repeatedly contacted two witnesses, in violation of the district court's gag order, in an effort to secure materially false testimony concerning the activities of the Hapsburg group.
The court found no clear error in the district court's finding that Manafort was unlikely to abide by any conditions of release. The court agreed with Manafort that the district court's finding that his communications violated the District Court for the Eastern District of Virginia's Stay-Away Order was problematic. However, the court found no clear error in the district court's ultimate finding that there were no conditions that would assure that Manafort would comply with the most fundamental condition of release under the Bail Reform Act: that he not commit a Federal, State, or local crime during the period of release.
This opinion or order relates to an opinion or order originally issued on July 12, 2018.
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