Last night, Michael Cohen’s lawyers filed a sentencing memorandum on his behalf. You can read it here. There are a couple of ledes buried in the thing at pages 20 and 21. This one at page 21 jumped out at me — in particular the phrase “and kept Client-1 apprised of these communications”:

Another thing, which is getting a lot of attention but may or may not be noteworthy: remember what Ken White said in The Atlantic:

They still might. Cohen admitted that he lied to Congress to support President Trump’s version of events. He notably did not claim that he did so at Trump’s request, or that Trump knew he would do it. But if Cohen’s telling the truth this time, then this conclusion, at least, is inescapable: The president, who has followed this drama obsessively, knew that his personal lawyer was lying to Congress about his business activities, and stood by while it happened.

That italicized “not” gets a lot less meaningful when you consider this passage at page 20, in which Cohen’s lawyer says that during the preparation of his dishonest testimony, he was in regular contact with White House staff and legal counsel:

It doesn’t say what he told them, which is why it may not be noteworthy. I have a feeling that question is going to get asked.

[Cross-posted at The Jury Talks Back.]