The Russia Connection

Document: Oct. 2 D.C. District Court Opinion Compelling Former Manafort Legal Counsel to Testify

By Matthew Kahn
Monday, October 30, 2017, 5:55 PM

On Oct. 2, Chief Judge Beryl A. Howell of the United States District Court for the District of Columbia issued an opinion compelling grand jury testimony from a witness, a former legal representative of two targets—apparently Paul Manafort Jr. and Richard W. Gates III. The targets invoked the attorney-client and work product privileges. However, Judge Howell finds that: The special counsel has made a sufficient prima facie showing that the invoked privileges are subject to the crime-fraud exception; disclosures made to the Department of Justice waive attorney-client privilege; and work-product privilege is overcome by adequate reasons to compel the witness testimony.