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Paul Manafort trial Day 4: Accountant testifies she helped falsify documents to help Manafort get loans

Former Trump campaign manager Paul Manafort is on trial for tax and bank fraud. The case has exposed his lavish spending on luxury clothes. (Video: Patrick Martin, Elyse Samuels/The Washington Post)

Follow our live updates on Day 5 of Paul Manafort’s trial in Alexandria here.

Paul Manafort, President Trump’s onetime campaign chairman, is on trial in federal court in Alexandria on bank and tax fraud charges. Prosecutors allege he failed to pay taxes on millions he made from his work for a Russia-friendly Ukrainian political party, then lied to get loans when the cash stopped coming in.

The case is being prosecuted by the special counsel investigating Russian interference in the 2016 U.S. presidential election.
Day four testimony included:

  • One Manafort accountant, Cindy Laporta, said she went along with falsifying his tax records because she feared confronting her longtime client.
  • Some of Manafort’s tax returns in the last decade did not reflect any foreign bank accounts, another accountant testified

Day 4 of Manafort’s trial: Accountants testify Manafort inflated loans, failed to disclose foreign accounts

5:09 p.m.: Testimony ends for day after defense wants weekend to prepare to question accountant

Asked if he would be able to finish his cross-examination by 5:15, Kevin Downing said he would be more “efficient” if he had the weekend to prepare.

Ellis told him that, despite anything he may have said implying otherwise, Downing is “not limited” in using the fact that Cindy Laporta testified under immunity from prosecution.

“She said on the stand she took responsibility, but she didn’t get prosecuted,” Ellis said. “I don’t know if there were professional consequences — that’s for you to find out.”

Prosecutors ended the day by saying they would not release the Manaforts’ tax returns yet, although they were entered into evidence yesterday, because defense attorneys have some concerns about personal information included.

Ellis said they can work that out, but “ultimately these tax returns are going to be in the public record. Once it becomes an exhibit in a trial, I think it has to be public.”

5:05 p.m.: Accountant made call to help Manafort with loan

Accountant Cindy Laporta has testified at length Friday about how Rick Gates sent her backdated documents in an effort to help Paul Manafort pay less in taxes and secure loans. In one such effort, Laporta said Manafort turned to her when his bookkeeper wouldn’t help.

The episode occurred in 2016, as Manafort was trying to get a loan from Federal Savings Bank, Laporta testified. At the time, Manafort’s company, DMP International, had losses of $638,000 on its profits and loss statement.

Laporta said – and emails show — Manafort contacted the accountant about obtaining a profits and loss statement that would reflect $2.4 million in income he earned in Ukraine and expected to be deposited in November. His bookkeeper, Laporta testified, would not note the income because she only counted cash once he had come in.

Asked by Assistant U.S. Attorney Uzo Asonye whether she believed Manafort actually was getting the money, Laporta responded, “I had no idea.” She said she asked for supporting documents.

Laporta said she never sent a profits and loss statement as Manafort requested, because she never got documents. But on August 11, 2016, she emailed Federal Savings Bank to say that Manafort expected the $2.4 million deposit. She testified that Manafort had directed her to do so.

4:54 p.m.: Accountant testifies she helped falsify documents to help Manafort get loans

Cindy Laporta is now testifying that she was involved the falsification of documents to help Paul Manafort obtain loans.

First, she said that although documents from Manafort’s bookkeeper showed that a property he owned in Lower Manhattan was being used as a rental in 2015 — he made $116,000 in income while also claiming depreciation — she told an employee of Citizens Bank it was a second home because Manafort could “get a better rate” on a loan that way.

Next, she testified that the same bank employee, David Fallarino, said Manafort needed more “liquidity” to qualify for a loan.

“The bank wanted to see more money available to pay back the loan,” she said.

So, she reached out to Gates, who told her a $1.5 million loan from Peranova Holdings in 2012 had been forgiven in 2015. She told that to Fallarino, who asked for “color” — ie, documentation.

Asked who directed her to say the loan was forgiven, she said “Mr. Manafort or Mr. Gates.” She relied on “their word,” she said.

Given her experience with the Telmar loan, prosecutor Uzo Asonye asked, did Laporta believe the loan had really been forgiven in 2015?

“Uh… no,” she replied.

When she asked for documentation, Gates told her he would send a draft and then the final version. Laporta said that was a good idea; under questioning from Judge Ellis she said she didn’t remember why she asked for a draft.
Gates sent her a Word document on Feb. 8, 2016, with that date in the file name. It was a letter from Peranova Holdings claiming the $1.5 million loan was forgiven on June 23, 2015.

Laporta believed “it was false” she said, “because of the dates.” She did not modify the document, she said after a pause, because “I wanted it to be the client’s document.”

Her implication was that she did not want to be more complicit in fraud than she already was.

Asked directly if she used the document in the bank negotiations despite believing it to be false, Laporta said, “Yes.”

4:38 p.m.: Emails cast doubt on Paul Manafort’s defense

Prosecutors provided email evidence to link Manafort to the misdeeds that Manafort’s defense attorneys have sought to blame on Gates. In one exchange following discussions about the loans, Manafort emails the accountant.

“Cindy, Have you what you need from Rick?” he wrote. Manafort then told her to call Gates, so he could move it “forward.”

4:11 p.m.: Accountant: Questionable loan saved Manafort $400,000 to $500,000 in taxes

Paul Manafort likely saved between $400,000 and $500,000 in taxes after his top deputy concocted a $900,000 loan to include on his businesses’ return for transactions in 2014, one of Manafort’s accountants testified Friday.

Cindy Laporta said the loan reduced Manafort’s income by $900,000, and at his tax rate, that would have resulted in a nearly half-million dollar savings. The testimony is important in that it shows the financial motivation that prosecutors say Manafort had to cook the books.

Laporta has been perhaps the most notable witness of the trial’s fourth day, essentially admitting she went along with tax fraud by Manafort and his deputy, Rick Gates. And through her testimony, prosecutors were able to show jurors documents that support their case.

One document, which prosecutors called an “adjusted trial balance,” showed how Manafort’s business, DMP International, initially made no reference to the $900,000 loan he would later claim on his taxes. But in a column for adjusted items, the $900,000 loan appeared. To support the change, an item initially listed as $900,000 in “other income” was reclassified as a loan in the books at Manafort’s business, Laporta testified.

Laporta testified she did not believe such a loan actually existed, because the first she heard of it was in a September 2015 conversation with Manafor’ts business partner Rick Gates. She said she asked Gates for documentation of it, and he provided just two pages, apparently documenting a March 2014 loan agreement between DMP International and a company called Telmar Limited. Prosecutors have alleged Telmar is a Cyprus company that Manafort controlled.

Notably, the loan document bore what Laporta said was Manafort’s signature. That is important because defense attorneys have sought to blame financial malfeasance on Gates, and much of Laporta’s testimony has focused on her interactions with him. Manafort’s signature would link him directly to the episode.

3:50 p.m. Accountant says she went along with alleged tax fraud because she was afraid to confront Manafort

Back on the stand after a break, Cindy Laporta wasted no time in admitting it was “wrong” to agree to increase the amount of a loan on Paul Manafort’s 2014 tax returns just before submitting them in 2015. The purported $900,000 loan came from an entity in Cyprus called Telmar Investments, which according to prosecutors Manafort controlled.

“I had a couple of choices at that point,” she said.

She had just had a conference call with Rick Gates in which he said Manafort could not afford to pay his taxes and so they had to be reduced, possibly by inflating the value of that loan.

“I could have refused to file the tax return,” which she said could lead to litigation with Manafort’s firm.

“I could have called Mr. Manafort and Mr. Gates liars, but Mr. Manafort was a long-time client of the firm and I did not want to do that either,” she said.

Asked if she regretted her actions, she agreed; “I very much regret it.” She said she was taking responsibility now.

3:42 p.m. Accountant testifies Rick Gates asked her to modify Manafort loan to decrease taxes

In remarkable testimony Friday afternoon, accountant Cindy Laporta described how Manafort’s business partner Rick Gates asked tax preparers during a call in 2015 to modify the amount of a loan so that Paul Manafort would have to pay less in taxes.

The call occurred in September 2015, though it was somewhat unclear which loan ultimately got modified. Confronted with a possible tax bill, Gates “said it was too high,” and that his boss, Paul Manafort, “didn’t have that money,” Laporta testified.

Assistant U.S. Attorney Uzo Asonye asked her what was proposed as a solution, and she responded “changing the amount of the loan.”

“He was trying to reduce income and therefore, income taxes,” Laporta testified.

Laporta testified such conduct was “inappropriate.”

“You can’t pick and chose what’s a loan and what’s income,” she said.

But prosecutors presented an email that showed a subordinate at her firm, Conor O’Brien, himself wrote,” The loan amount may need to be changed.”

They ultimately decided on a $900,000 amount because “it resulted in a tax amount that Rick said could be paid,” Laporta testified.

3:17 p.m.: Accountant testifies she didn’t believe Manafort on loans

As the afternoon waned, prosecutor Uzo Asonye began pressing Manafort’s former accountant Cindy Laporta to detail financial arrangements that prosecutors allege Manafort and his business partner, Rick Gates, used to evade paying taxes, including classifying income from foreign companies as “loans” to themselves.

Laporta testified that she was suspicious of the loans, many of which were thinly documented.

“Did you have concerns about representation you received about these foreign loans?” Asonye asked.

“Yes,” she said.

“Did you believe the representations about these foreign loans?”

“No,” she said.

2:59 p.m. Another accountant says Manafort kept tax preparers in the dark

Cindy Laporta, like accountant Philip Ayliff before her, said Paul Manafort never told her about control over foreign companies and bank accounts or about any accountants and tax preparers he had in Cyprus.

Asked if she and Ayliff would have wanted to know that information, Laporta confirmed that they would: “We would always want to know the full picture.”

Here are six things you need to know about Paul Manafort’s trial

As he did with Ayliff, prosecutor Uzo Asonye went through a list of over a dozen foreign companies and asked if she knew Manafort controlled them; she said no. When those companies showed up on his tax returns, she said, they appeared as Manafort’s foreign clients — because that’s what bookkeeper Heather Washkuhn recorded them as.

Asonye showed one email from Oct. 4, 2016 in which Laporta asks Manafort specifically whether he had foreign accounts; the answer was “NONE.”

Laporta said had she known Manafort had control of the foreign companies and bank accounts, “That would require reporting.” She too said the accounting firm put more emphasis on foreign bank account reporting around 2012 when the Department of Justice began cracking down on them. It was mentioned in the firm’s annual engagement letters, she said, and they made sure to ask about it annually rather than simply ask whether anything had changed from the previous year.

2:47 p.m.: Despite the stakes, Manafort still looks relaxed

Paul Manafort wore a blue suit, blue shirt and purple tie to court Friday, and chatted amiably with his attorneys upon entering.

He has looked engaged throughout the proceedings – sometimes taking notes, sometimes looking at the attorneys or the witnesses and sometimes folding his hands in front of his face, staring straight ahead. Once on Thursday, he even corrected his own attorney when the attorney told the judge the wrong exhibit number.

“257,” Manafort told the attorney.

From six homes to a city jail: Paul Manafort, who redefined lobbying, faces trial

Even as testimony has turned to complicated tax matters, jurors have also appeared engaged. Several are taking voluminous notes in black writer’s notebooks, and virtually all look at the monitors in front of them as prosecutors and defense attorneys zoom in on particular sections of documents they are seeking to highlight.

The courtroom – a mere seven rows of wooden benches underneath half-orb lights hung from the ceiling by gold posts — is almost completely full. Journalists are crammed shoulder to shoulder with courthouse observers.

2:36 p.m.: Prosecutors call first witness to testify under immunity agreement

Prosecutors called as their 14th witness Cindy Laporta – another of Manafort’s accountants. She is the first person to testify under an immunity agreement with the special counsel to prevent her from facing possible legal exposure about what she might say.

Laporta signed Manafort’s tax returns in 2014 and 2015, taking over for Philip Ayliff when he retired from their firm. With her early testimony, prosecutors sought to show jurors that Manafort – rather than Laporta, his bookkeeper or business partner Rick Gates – were responsible for inaccuracies in his tax documents, and Manafort knew that.

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Laporta said her firm gave Manafort a letter making clear they were not “auditing or verifying” the information clients provided – and while they offered that service, Manafort used the firm only to prepare his returns. She said she gathered information from Manafort, Gates and his bookkeeper, and “Mr. Manafort approved that.”

Laporta testified she viewed Gates as Manafort’s “assistant.”

Asked by Assistant U.S. Attorney Uzo Asonye who was in charge, she said, “Mr. Manafort,” though she noted Gates often gave her information.

That assertion might have been helpful to the defense, which has sought to cast blame for financial irregularities on Gates.

To rebut that, prosecutors showed Laporta a September 2015 email of Manafort forwarding Gates tax documents, which Gates forwarded on to her. She testified that was typical of how she would get Manafort’s tax documents.

A total of five witnesses have been granted immunity to testify at Manafort’s trial.

2:09 p.m. Lead defense attorney speaks before jury for first time

Lead defense attorney Kevin Downing’s cross-examination of Philip Ayliff is his first time speaking before the jury in this case. He did not get through his first question before a member of the special counsel shot up with an objection.
Downing started by saying he would be going slowly, because “when we talk about these tax and accounting issues, I look over at the jury –”

Assistant U.S. Attorney Uzo Asonye cut him off, objecting to that characterization.

Downing is of course very familiar with tax and accounting issues; he spent 15 years in the DOJ’s tax division and was actually behind an effort Ayliff described earlier to crack down on unreported foreign bank accounts.

Here, defending Manafort, he asked whether those reporting requirements are sometimes hard to understand.

He asked Ayliff, Manafort’s former accountant, whether “that was a lot more complicated than determining whether there was signature control” over a foreign bank account.

Ayliff agreed, saying he was a “generalist” but sometimes roped in other accountants at the firm who specialized in foreign tax issues when dealing with Manafort.

The emails Downing used to make his point, which were entered into evidence by the government, focus on one foreign telecommunications firm in which Manafort was invested but did not have signature authority. The accountants determined that his investment was not large enough to trigger reporting of a foreign bank account.

However, prosecutors are alleging Manafort had total control over dozens of foreign accounts.

Still, Manafort’s attorney again attempted to shift responsibility to Rick Gates.

“Were you backed up year in and year out against filing deadlines?” Downing asked.

“Yes,” Ayliff said. “Did you have difficulty getting information?” Downing asked. “Yes,” Ayliff said. “Primarily that information was provided by Mr. Gates, is that correct?” Downing asked. “Yes,” Ayliff said.

Downing displayed a financial document, atop which sat large block letters proclaiming “This is a loan … per Rick Gates call.”

1:53 p.m. Judge gets combative with prosecutors, again

As he has been throughout the trial, Judge T.S. Ellis III was notably combative with prosecutors Friday.

More than once the judge, slouching forward in a roller chair pivoted slightly to one side, critiqued the questions asked by Assistant U.S. Attorney Uzo Asonye. When Asonye asked Paul Manafort’s tax documents preparer, for example, about the accounting methods generally used to prepare tax returns, Ellis told him to make the inquiry more specific.

“Why don’t you ask him on what basis he prepares them on?” Ellis said.

Another time, as Asonye asked broadly about the accountant’s role in putting together Manafort’s tax return, Ellis cut him off. Of course, the judge said, Philip Ayliff was involved in putting together the tax return. Asonye was trying to highlight that Manafort, though, was the one to sign and mail in the document.

“The correct question would be, ‘Did you have any role in mailing it in?’” Ellis said.

Who is Judge T.S. Ellis III?

Prosecutors have mostly kept their composure in responding to Ellis’s jabs, though the judgeseemed to get under their skin at least once on Friday. The flare-up came when Asonye tried to enter a piece of evidence that was described inaccurately on the list of exhibits Ellis had been given.

“May we approach,” Asonye asked, saying he could clear up the confusion.

“Is it a mistake?” the judge shot back, glowering at the attorney. When Asonye responded with only silence, Ellis relented. “All right. Yes. You can,” he said.

In a huddle next to Ellis’s bench, another prosecutor, Greg Andres, stood close to the judge and gestured emphatically with one of his hands. Though white noise in the courtroom made the conversation impossible to hear, Andres seemed to be speaking animatedly. Ellis soon returned to the bench and told jurors not to worry too much about the episode.

“It’s not a big deal,” he said. “It’s no big mistake.” He explained that there “may be an error in the description” of the item that they would soon to be shown.

“These things happen,” Ellis said. Asonye soon resumed questioning the tax documents preparer.

12:58 p.m.: Attorney: Paul Manafort would not have left evidence ‘around’ if he was trying to break law

During a break, Paul Manafort’s lead attorney Kevin Downing offered a bit of Manafort’s defense on charges of failure to report foreign banks accounts. Essentially, he argued that if Manafort had known he was doing something illegal, he wouldn’t have been so easy to catch.
“Nobody intending to violate the law would leave the evidence around for his accountant to find it,” Downing said in court.
Judge T.S. Ellis III made the same point, summarizing the defense as, “There’s a trail in these documents that would lead to the truth, and somebody who violated the law wouldn’t have done that.”
The trial is on lunch break until 1:30 p.m.

12:53 p.m.: Tax preparer discusses Manafort’s rental properties

The prosecution finished its questioning of tax documents preparer Philip Ayliff by asking about properties Paul Manafort claimed as rentals on his taxes. That evidence is important because, in seeking to get loans, Manafort attempted to claim these properties were for personal use, which could be evidence of bank fraud.

Assistant U.S. Attorney Uzo Asonye showed jurors an email Manafort sent to Ayliff telling him the bank UBS was raising questions as he attempted to get a loan. Particularly, Manafort told his tax documents preparer, the bank was asking about documents that appeared to show a property on Fifth Avenue in New York, was a rental, when Manafort claimed it was personal.

“It was my understanding it was a rental,” Ayliff testified. “It had always been a rental.”

Asonye showed jurors emails that Manafort had treated a property on Howard Street was used as a rental in 2015 – even though he would claim otherwise in trying to seek a loan. Tax returns show Manafort claimed to have made $115,000 in rental income that year from the property, and he claimed depreciation to reduce his tax obligation.

12:30 p.m.: Tax prepaper delves into suspicious loan

Accountant Philip Ayliff testified that his firm asked Paul Manafort and Rick Gates for documentation of $1.5 million loan from Peranova Holdings in 2012 and got none.

“There normally wasn’t a response,” when the accounting firm, Kositzka Wicks & Company, asked about loans to Manafort’s consulting firm, Ayliff said. “They just said it was a loan.”

It was Rick Gates, Manafort’s deputy, who told the firm in a conference call that $1.5 million should be classified as a loan, Ayliff testified.

“We’d never heard of Peranova Holdings,” Ayliff testified. “We thought it was an independent third party.”

In fact, prosecutors have shown evidence Manafort used Peranova, based in Cyprus, to pay his personal expenses.
Had Ayliff known the $1.5 million was payment for work in Ukraine, the accountant said, on Manafort’s taxes “it would have been income.” Ayliff also said “if they had control over” Peranova, that would also have affected the tax return reporting.

Ayliff said the accountants also asked about the loan in subsequent years, because there were no payments towards it. “We would ask, ‘What’s the status of the loan, is it still outstanding?'” They were told it was.

He said no one at the firm told Manafort or Gates to treat loans as income to lower their tax burden.
Ayliff also testified that Manafort’s spending on suits, home improvement, landscaping, and property should have been classified as personal rather than business expenses.

11:12 a.m.: Tax preparer: Manafort did not report foreign accounts containing millions

In early testimony Friday, the prosecution sought to highlight how Paul Manafort repeatedly denied having foreign banks accounts – even though previous witnesses have testified he used foreign accounts to fund his lavish lifestyle.

With tax documents preparer Philip Ayliff still on the stand, Assistant U.S. Attorney Uzo Asonye flashed for jurors each of Manafort’s tax returns from 2010 to 2014. As jurors peered down at the monitors in front of them in the jury box, Asonye asked Ayliff if Manafort had reported about whether he had any foreign bank accounts.

[See Paul Manafort’s tax documents]

“None,” Ayliff said, repeating the exercise five times.
Asonye then turned to emails between Manafort, business partner Rick Gates and their tax documents preparer, attempting to show it wasn’t just on the returns themselves that Manafort had claimed not to have foreign accounts. One 2011 email showed Ayliff writing to Manafort, asking if he had any interest in a foreign bank account. Manafort responded he did not.

The testimony is important because Manafort is charged with, among other things, failing to report foreign bank accounts as he was legally required to do. Prosecutors must show Manafort’s failing to do so was no mere mistake.

Other emails showed the tax documents preparer inquiring about transactions involving foreign accounts.
In August 2009, for example, he wrote Manafort inquiring about a $1 million transaction that came from Deustche Bank to LOAV Advisors Limited. Jurors saw similar inquiries directed to Gates.

The tax documents preparer said his firm relied on the representation of Gates, Manafort and their books, and the men never told him of accounts or tax information from Cyprus. Jurors already have heard that Manafort made payments from accounts in that country.

Ayliff said he believed the foreign companies were clients of Manafort’s; he did not think Manafort controlled them.

“They never told us about any income that was deposited in foreign accounts,” he said.

10:46 a.m.: With accountant, prosecutors get into the meat of tax crimes

Prosecutors have now gotten to the nitty-gritty details of Paul Manafort’s alleged tax fraud, going through business and personal returns from 2010 to 2014 with one of his former accountants.
Jurors saw each year’s returns for both Manafort’s consulting firm, Davis, Manafort Partners Inc. (later DMP International) and the personal returns for Manafort and his wife, Kathleen.

[See Paul Manafort’s tax documents]

For each of those years, even as the firm reported large receipts, the firm’s reported profits were a fraction of that amount because of high business expenses.

Prosecutors allege Manafort lowered his tax burden by disguising some income as loans, and highlighted one such loan from 2012 — $1.5 million from one of the Cyprus companies the government says he controlled, Peranova Holdings Limited.

On Wednesday Manafort’s bookkeeper Heather Washkuhn testified that his deputy Rick Gates told her in 2016 the loan had been forgiven and should be treated as income on his 2015 returns. That was done, prosecutors say, to inflate Manafort’s income so he could get an actual loan.

Still, in the years he was working in Ukraine, Manafort reported making quite a healthy income. On his individual returns, in 2010 Manafort reported $504,744 in income in 2010.

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In 2011, it was $3,071,409. In 2012, $5,361,007. In 2013, $1,910,928, and in 2014, $2,984,210. But, accountant Philip Ayliff testified, Manafort reported having no foreign bank accounts — which is where prosecutors say the defendant was stashing many millions more from Ukraine.

Ayliff is the first witness that Kevin Downing, Manafort’s lead attorney, plans to cross-examine.

Judge Ellis has been a bit softer on prosecutors now that they are delving into the true heart of the case. But he continued to interrupt. When Assistant U.S. Attorney Uzo Asonye asked if Ayliff had any role in Manafort’s gift tax returns, Ellis interjected, “The correct question would be, did you have any role in mailing them?”

10:14 A.M.: Trial resumes with Manafort’s tax preparer taking the stand

Jurors returned to the courtroom just after 9:45 a.m. to hear more testimony from Philip Ayliff, Paul Manafort’s tax documents preparer.

After establishing Ayliff’s long relationship with Manafort – the tax preparer said he began working for Manafort in 1997, and met with him 30 times over the two decades since – Assistant U.S. Attorney Uzo Asonye drilled into what Ayliff knew about Manafort’s business partner, Rick Gates. Ayliff said Gates was “working closely with Mr. Manafort,” and was Manafort’s “right hand” adviser.

Who was in charge, Asonye asked.

“Oh!” Ayliff exclaimed, then added decisively, “Mr. Manafort.”

That is important because defense attorneys have sought to cast Manafort as a dupe of Gates. Ayliff seemed to cast doubt on that idea. He said he never saw Gates confront Manafort, or vice versa. Nor, he said, did Gates ever tell him to hide anything from Manafort. He said the two men often conducted calls together where he would discuss their taxes.

9:46 a.m.: Special counsel attorney gets guilty plea (no, it’s not Paul Manafort)

An attorney for the special counsel’s office appeared in court early Friday as part of a hearing on a guilty plea. But no, it wasn’t Paul Manafort.

Assistant U.S. Attorney Uzo Asonye, one of the lawyer’s prosecuting Manafort, is working an unrelated case at the same time. Asonye was there to hear a guilty plea from a contractor, who admitted to falsifying tests on the D.C. area’s Metro’s Silver Line project.

“Doing double duty, Mr. Asonye,” Judge T.S. Ellis III joked at the outset. Later he asked if Asonye was familiar with a recent Supreme Court ruling on restitution.

Asonye, whom Ellis has chided and interrupted throughout the Manafort trial, responded, “I’m always available to be educated by the court.”

9:24 a.m.: Prosecutors: We’re going to need to use charts

The special counsel’s office on Friday morning told a federal judge they intend to use “summary charts” to help explain their complicated case against Paul Manafort.

The brief request lays out the breadth of investigative work the special counsel conducted in investigating Manafort. Prosecutors wrote that an FBI forensic accountant reviewed “tens of thousands of documents containing thousands of entries, from approximately 20 financial institutions and 35 companies” to make the charts, which prosecutors said summarize Manafort’s purchases and payments from foreign and U.S. bank accounts.

They said they are alleging that Manafort controlled “17 domestic entities, 12 Cypriot entities, and three other foreign entities, and he “caused over 200 wires to be sent from those entities to domestic bank accounts, entities, or vendors.”

Judge T.S. Ellis III still has to approve the request. Prosecutors wrote that this was the “prototypical” case to do so because of its complexity.

8:57 a.m.: What to Expect Day 4

On the third day of Paul Manafort’s trial, jurors heard more testimony and reviewed more evidence about his lavish lifestyle. They learned he had a $20,000 video and karaoke system installed in one of his homes, and that he spent hundreds of thousands of dollars on landscaping that included a flower bed in the shape of the letter “M.” As they had been on previous days, jurors were told the purchases were paid for with wired money from foreign bank accounts.

Jurors also for the first time heard from two of the people Manafort tasked with handling his finances – a bookkeeper and an accountant. The bookkeeper began to describe the bank fraud of which Manafort is accused. The accountant’s testimony is expected to continue Friday. He is the 13th witness to testify.

As the trial enters its fourth day, the biggest question will be when Rick Gates, Manafort’s business partner, will take the stand. Prosecutors had earlier in the trial suggested his testifying was not a foregone conclusion, but they affirmed Wednesday that they intend to call him to the witness stand. His testimony will be critical. Gates was accused in the same indictment as Manafort, and prosecutors will rely on him to describe the fraud they say he and his partner carried out.

Manafort’s defense, meanwhile, has sought to cast Gates as a liar who embezzled from Manafort and then tried to cover his tracks. Gates pleaded guilty to conspiracy and lying to the FBI earlier this year.

Through witnesses, prosecutors have laid out the broad outlines of their case. They say Manafort got rich based on work in Ukraine, lived extravagantly while paying no taxes on the money, and then – when the worked dried up – committed bank fraud to maintain his lifestyle. But witnesses still need to fill in some of the details and demonstrate more forcefully that Manafort sought to deceive banks and the IRS.

Testimony is set to resume at 9:30 a.m.