They said Manafort, who has been jailed since June, had already suffered greatly for his crimes. At age 69, plagued by health problems, he poses no risk of recidivism, they said.

Their sentencing memorandum, the second they filed this week, was submitted to Judge T.S. Ellis III of U.S. District Court in Alexandria, Viriginia. Ellis will sentence Manafort on Thursday for tax fraud, bank fraud and other financial crimes. The next week, he will be sentenced by Judge Amy Berman Jackson in a related conspiracy case in U.S. District Court in Washington.

Advisory sentencing guidelines set Manafort’s punishment at 19 to 24 years in the financial fraud case. While they recommended no specific sentence, prosecutors working for the special counsel, Robert Mueller, have said they agreed with that calculation by the federal probation office.

But Manafort’s lawyers argued that such a punishment would be far too severe, asking for a sentence “significantly below the advisory guidelines.” They cited a string of cases of other defendants who were sentenced to probation or imprisoned for less than a year for similar schemes involving millions of dollars of income hidden away in overseas bank accounts.

Prosecutors have described Manafort as a bold, hardened criminal motivated purely by greed. The special counsel’s office has also asked that Ellis take into account the recent finding by Jackson that Manafort lied to prosecutors after he pleaded guilty to the conspiracy charges in September and agreed to cooperate with them.

Earlier this week, citing new information from a cooperating witness, prosecutors appeared to correct one element of their allegations that Manafort had lied to them about his contacts with a Russian business associate whom they have linked to Russian intelligence.

Manafort’s lawyers seized upon that apparent admission of an error, telling Ellis that the prosecutors’ revised account of their evidence cast Manafort in a more favorable light.

But just as they filed their pleadings, Jackson ruled that she stood by her conclusion that Manafort had lied about his interactions with the Russian associate, Konstantin Kilimnik, as well as about two other matters.