now he will have the chance to respond, paul manafort. but just the litany of things that mueller's prosecutors said that he purposefully lied about even after the plea deal. it's stunning. >> reporter: the memo is not long, but it is pretty succinct in laying out paul manafort's crimes saying he lied to tax prepare preparers, members of the executive branch. they described he was a repeatedly committing the crimes and over a decade and he continued even after he pleaded guilty and while he was donald trump's campaign chairman. in particular, on the guilty plea the special counsel's office wrote that manafort's conduct after he pleaded guilty reflects a hardened adherence to committing crimes and lack of remorse. it's that lack of remorse and threat of resitivism if manafort doesn't get a long term prison