Document: Government Memo on Manafort and Gates Conditions of Release, Case Designation and Notice of Intent to Use Bank Records

Shannon Togawa Mercer
Tuesday, October 31, 2017, 11:54 PM

On Oct. 31, the government filed a memorandum in United States of America v. Paul J. Manafort, Jr. and Richard W. Gates III, to advise the court of three issues prior to the scheduled Nov. 2, 2017 court appearance.

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On Oct. 31, the government filed a memorandum in United States of America v. Paul J. Manafort, Jr. and Richard W. Gates III, to advise the court of three issues prior to the scheduled Nov. 2, 2017 court appearance. First, the government outlines the current bail conditions facing the defendants, arguing that the court should find that the defendants pose a "serious risk of flight." Second, the government asks the court to designate this case "complex" under the Speedy Trial Act, 18 U.S.C. § 3161(h)(8)(B)(ii), impacting the timeline of trial. Last, the government provides the defendants notice pursuant to 18 U.S.C. § 3505 of its intent to use specific foreign bank records, or a "foreign record of regularly conducted activity," in the impending proceedings.


Shannon Togawa Mercer is a senior associate at WilmerHale. Her practice focuses on complex global data protection, privacy, and cybersecurity matters. Ms. Togawa Mercer has extensive experience counseling clients on cross border data protection and privacy compliance as well as cyber incident response. She has practiced in London and Washington D.C. and previously served as Managing Editor and Senior Editor at Lawfare. Ms. Togawa Mercer also served as National Security and Law associate at the Hoover Institution.

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