During his testimony Monday, Gates admitted he had embezzled money from Manafort by creating false expense reports on his own behalf. The crimes Manafort allegedly committed do not have bearing on that central question, but they were uncovered in the course of the special counsel investigation; this is the first trial resulting from Mueller's probe.
On Tuesday, the court was shown a series of emails, contracts and what prosecutor Greg Andres referred to as "fake invoices", in which Gates altered the template to show the name of a shell company instead of Manafort's. And the witness never did.
The question was cut off and Judge T.S. Ellis had a private conversation with the attorneys, out of earshot of the jury.
Cindy Laporta, one of the accountants, also testified that Manafort and Gates had used phony loan documents to improperly reduce Manafort's income and lower his tax bill.
NBC's Pete Williams also reported that prosecutors want Ellis to "explain to the jury that he was out of line when he reprimanded them over allowing an IRS agent witness to watch other testimony", according to NBC's Ken Dilanian.
Paul Manafort's attorney Kevin Downing on Wednesday asked whether longtime Manafort deputy Rick Gates had four extramarital affairs - and not just one overseas 10 years ago - implying that Gates might have lied to special counsel Robert Mueller's team and could put his plea deal in jeopardy.
Manafort couldn't have followed his income "that closely" since Gates had "stolen" hundreds of thousands of dollars from him, Ellis said.
"After all the lies you've told and the fraud you've committed, you expect this jury to believe you?"
Defense attorney Kevin Downing had asked Gates, "Were you interviewed on several occasions about your time at the Trump campaign?"
Downing responded that the question goes to whether Downing told the truth to the special counsel or whether the plea agreement should be ripped up - potentially devastating to the government's case and to the public perception of special counsel Robert Mueller's investigation into Russian election interference. "Mr. Manafort had the same path".
Sarri set for talks over potential move for Zaha later this week
Williams and Kaikai will both be hoping to remain at Palace and avoid being sent out on loan before Thursday's 5pm transfer deadline.
The judge's comments were in response to a written filing by prosecutors arguing that Ellis should instruct the jury that he made an error in admonishing them during the Wednesday testimony of IRS agent Michael Welch.
Downing accused Gates of using the funds he admitted to stealing from Manafort to pay for a lavish lifestyle that included a London apartment and travel funds to finance one of his extramarital affairs.
Magionos testified that she reviewed 31 accounts tied to Manafort in Cyprus, St. Vincent and the Grenadines and the United Kingdom, and Manafort was listed as the beneficial owner on at least some of them.
Gates' earlier testimony on Tuesday, meanwhile, centered on how Ukrainian businessmen paid Manafort for his consultancy work. Prosecutors agreed to drop a wide variety of additional charges against Gates in exchange for his guilty pleas and cooperation against Manafort.
All three testified that Manafort and Gates failed to tell them about the foreign holdings in Cyprus.
But in reality, Manafort rented out the Howard Street loft on Airbnb for more than a year - as an "Amazing full floor loft in SoHo" - and still had a mortgage on the Brooklyn brownstone, James said.
Manafort and Gates hid the fact that one property had a mortgage against it and falsely claimed that another property was a second residence for Manafort and his daughter, James said.
The prosecution has put forward more than 20 witnesses - including Manafort's longtime deputy Rick Gates - and a trove of documentary evidence as they've sought to prove Manafort defrauded banks and concealed millions of dollars in offshore bank accounts from the IRS.
Manafort, who helped Republicans Gerald Ford and Ronald Reagan reach the White House, was Mr Trump's campaign chairman from May to August 2016.
Manafort attorney Richard Westling also attempted to sow doubt in Magionos's testimony regarding the authenticity of the Manafort signature on various documents that were presented.