During the Jan. 16 discussion, Jackson also admonished Downing for a letter that Manafort gave to the Pretrial Services Agency from his doctor, which hadn’t been filed on the docket — Jackson said the letter was basically asking for a change in Manafort’s conditions of release, and should have been filed.

“You don't send me messages through other people in the building. If you want to communicate with the Court, you docket something,” Jackson said.

Later in the public portion of the hearing, the judge addressed the letter and said those sorts of requests needed to be filed on the docket. She hinted at what it was about, telling Downing, “I will note from the record that while he's subject to home confinement, he's not confined to his couch. And I believe he has plenty of opportunity to exercise.”