Former Trump campaign chairman Paul Manafort filed a sentencing memorandum on Monday asking the court for “a sentence significantly below the statutory maximum sentence.”

Manafort is currently facing a potential sentence of 188 to 235 months in prison after pleading guilty to one count of “conspiracy against the United States” and one count of conspiracy to obstruct justice. The memorandum states that the maximum sentence would result in a life sentence for Manafort due to health concerns.

The sentence is argued as being harsh for a Foreign Agents Registration Act (FARA) violation. Manafort is only the seventh time criminal charges have been filed for a FARA violation since 1966. It is also the first time a FARA violation was used to charge a money laundering conspiracy.

The memorandum also states that the charges are the results of actions prior to Manafort’s time as campaign chairman in 2016. It is specifically stated that Manafort “has not been charged with any crimes related to the primary focus of the Special Counsel’s investigation.” The memorandum also specifies that “but for the appointment of the Special Counsel and his Office’s decision to pursue Mr. Manafort for a rarely prosecuted FARA violation, Mr. Manafort would not have been indicted in the District of Columbia.” If it was not for the Special Counsel investigation, the memorandum argues that a FARA violation would likely have resulted in Manafort simply registering with the National Security Division.

It is argued that a long prison sentence is not “necessary to prevent [Manafort] from committing further crimes” due to the personal and financial devastation that Manafort has experienced due to his conduct. Manafort also showed remose and responsibility and “the general public have been deterred from engaging in similar conduct.” The memorandum also requests that any sentence be served concurrent with any sentence imposed by the Eastern District of Virginia, which is currently pursuing a tax fraud case against Manafort.

The Special Counsel also released their own memorandum on the sentencing on Monday. The sentencing in the Eastern District of Virginia was delayed in January pending the DC case.