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In this Aug. 31, 2018, photo, W. Samuel Patten leaves the federal court in Washington, Friday, Aug. 31, 2018.   Washington political consultant initially entangled in the Russia investigation was sentenced to three years of probation for illegal lobbying and skirting the ban on foreign donations to President Donald Trump’s inaugural committee. (AP Photo/Jose Luis Magana) **FILE**

In this Aug. 31, 2018, photo, W. Samuel Patten leaves the federal court in Washington, Friday, Aug. 31, 2018. Washington political consultant initially entangled in the Russia investigation was sentenced to three years of probation for illegal lobbying and skirting the ban on foreign donations to President Donald Trump’s inaugural committee. (AP Photo/Jose Luis Magana) **FILE**

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