Executive Branch

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

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

A memorandum opinion from Judge Beryl Howell related to the grand jury testimony of a former lawyer for Paul Manafort.

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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.


Matthew Kahn is a third-year law student at Harvard Law School and a contributor at Lawfare. Prior to law school, he worked for two years as an associate editor of Lawfare and as a junior researcher at the Brookings Institution. He graduated from Georgetown University in 2017.

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