Monthly Archives: October 2019

Ty Clevenger v Department of Justice stay for Deborah Sines deposition, Seth Rich case prosecutor, “DOJ was willing to hide records….to conceal the misconduct of senior FBI and DOJ officials.”

Ty Clevenger v Department of Justice stay for Deborah Sines deposition, Seth Rich case prosecutor, “DOJ was willing to hide records….to conceal the misconduct of senior FBI and DOJ officials.”

“Instead of doing so, the government has continued to defy its
constitutional, ethical and legal obligations to this Court and to the defense, and to hide evidence that it knows exonerates Mr. Flynn. As is the essence of the problem here, instead of protecting its citizens, the “government” is protecting its own criminal conduct and operatives.”…Attorney Sidney Powell October 23, 2019

Mueller, as a matter of determined policy, omitted key steps which any honest investigator would undertake. He did not commission any forensic examination of the DNC servers. He did not interview Bill Binney. He did not interview Julian Assange. His failure to do any of those obvious things renders his report worthless.”…Craig Murray

“Fox News news analyst Ellen Ratner relayed information from Wikileaks founder Julian Assange to Texas businessman Ed Butowsky regarding Seth Rich’s role in transferring emails to Wikileaks, according to an amended lawsuit that I filed this morning on behalf of Mr. Butowsky.”…Attorney Ty Clevenger

 

From TY CLEVENGER,
Plaintiff,
vs.
U.S. DEPARTMENT OF JUSTICE, et al

UNOPPOSED MOTION FOR STAY

“At the telephone hearing held on October 18, 2019, the parties discussed public
statements made by Deborah Sines, the retired prosecutor who was formerly assigned to the Seth Rich murder case in Washington, D.C. The Court noted that Ms. Sines’s statements were not made under oath, further suggesting that the Plaintiff might try to obtain a sworn statement from Ms. Sines. The Plaintiff represents Ed Butowsky of Plano, Texas in some related cases pending
in the Eastern District of Texas, see Edward Butowsky v. Michael Gottlieb, et al., Case No. 4:19-cv-00180 (E.D.Tex.) and Edward Butowsky v. David Folkenflik, et al., Case No. 4:18-cv-00442, and the undersigned intends to subpoena Ms. Sines for a deposition.1 For that reason, the Plaintiff moves the Court to stay this case until the deposition of Ms. Sines can be arranged and the transcripts can be produced. The Plaintiff conferred with counsel for the Defendants via
email on October 24, 2019, and they do not oppose this request.

Separately, the Plaintiff requests that the Court take judicial notice of recent
developments in two other cases. In a reply filed on October 24, 2019 in United States v. Michael T. Flynn, Case No. 1:17-cr-00232-EGS (D.D.C.), attorney Sidney Powell laid out damning evidence that high-ranking FBI officials systematically tampered with records and hid exculpatory evidence for the purpose of framing the defendant, retired General Mike Flynn. The
reply itself is sealed, but Ms. Powell publicly posted a redacted version online, and the Plaintiff has attached a copy as Exhibit 1. The Plaintiff requests that the Court take judicial notice of that attachment or obtain a copy of the reply (and its exhibits) directly from the D.C. court.

As the Court is probably aware, the criminal charges against General Flynn are an integral part of the “Russian collusion” allegations against the Trump Administration, and allegations about Seth Rich are part of the same story.”

“It appears that the FBI was willing to conceal records and tamper with evidence in order to frame a highly-decorated former military officer, all for the purpose of promoting and protecting the “Russian collusion” narrative. Likewise, it appears that DOJ was willing to hide records related to “Russian collusion” in order to conceal the misconduct of senior FBI and DOJ officials. Taken together, these developments cast new light on the FBI’s refusal to search for
records about Seth Rich in the locations where they most likely would be found, i.e., it appears to be yet another attempt to conceal evidence related to the “Russian collusion” allegations.”

Read more:

https://www.courtlistener.com/recap/gov.uscourts.nyed.414614/gov.uscourts.nyed.414614.48.0.pdf

 

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https://citizenwells.com/

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Sidney Powell for Michael Flynn request for Joseph Mifsud data and other Brady material, Government response October 29, 2019, “not…material to the defendant’s guilt”???

Sidney Powell for Michael Flynn request for Joseph Mifsud data and other Brady material, Government response October 29, 2019, “not…material to the defendant’s guilt”???

“Mr. McCabe pointed to Mr. Flynn’s “very public interactions with Vladimir Putin and other Russians.” These “interactions” seem to have arisen from the work of CIA/FBI operatives Stefan Halper and Joseph Mifsud”…Sidney Powell motion October 25, 2019

“Instead of doing so, the government has continued to defy its
constitutional, ethical and legal obligations to this Court and to the defense, and to hide evidence that it knows exonerates Mr. Flynn. As is the essence of the problem here, instead of protecting its citizens, the “government” is protecting its own criminal conduct and operatives.”…Attorney Sidney Powell October 23, 2019

Mueller, as a matter of determined policy, omitted key steps which any honest investigator would undertake. He did not commission any forensic examination of the DNC servers. He did not interview Bill Binney. He did not interview Julian Assange. His failure to do any of those obvious things renders his report worthless.”…Craig Murray

 

I guess the prosecutors in the US v Michael Flynn case are desperate (or just corrupt and covering each other’s asses).

A pre law or for that matter average middle school student could blow their latest argument out of the water.

Attorney Sidney Powell will.

And the judge, if not too corrupt, should see it as another prosecution ploy to subvert justice.

From the motions:

“The United States of America, by and through its undersigned counsel, respectfully files this response to defendant Michael Flynn’s Motion to Produce Newly Discovered Brady Evidence, United States v. Flynn, 17-cr-232 (Doc. 124) (D.D.C. Oct. 15, 2019). In the motion, the defendant requests information pertaining to two phones that allegedly “were used by Mr.Joseph Mifsud” and are allegedly in the possession of the government. Id. at 2. According to the
defendant, the phones contain information on individuals tasked against the defendant as early as 2014. Id. 1

The requested materials are not favorable and material to the defendant’s guilt or punishment, or even relevant to this criminal case.”

https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.130.0_8.pdf

“In an extraordinary reversal, the defendant now claims that he is innocent of the criminal charge in this case. See, e.g., Reply at 2 (“When the Director of the FBI, and a group of his close associates, plot to set up an innocent man and create a crime . . . .”). For the first time, the defendant represents to this Court that he “was honest with the agents [on January 24, 2017] to the best of his recollection at the time.” Reply at 23. He makes this claim despite having admitted his guilt, under oath, before two federal judges (including this Court). The defendant also argues—based almost entirely on evidence previously provided in discovery—that the government engaged in “conduct so shocking to the conscience and so inimical to our system of justice that it requires the dismissal of the charges [sic] for outrageous government conduct.”
Reply at 2. The Reply then seeks a new category of relief, that “this Court . . . dismiss the entire prosecution for outrageous government misconduct.”1
Reply at 32.”

https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.131.0_2.pdf

From Sidney Powell’s motion filed October 25, 2019.

The Mueller Report established that there was no conspiracy between anyone in the Trump campaign and Russia. It is also apparent now, or will be upon the release of the FISA report of the Inspector General, that the FBI and DOJ had no legal basis to obtain a FISA warrant against Carter Page or to investigate Mr. Flynn.13 Yet, the government wants us to accept its word that the defense has everything to which it is entitled. Fortunately Brady exists to protect the accused
“from the prosecutor’s private deliberations, as the chosen forum for ascertaining the truth about criminal accusations.” Kyles v. Whitley, 514 U.S. 419, 440 (1995).

While Flynn was cooperating extensively on all issues the Special Counsel wanted to address, the government has trickled out productions over the last year that reveal many things. Ex. 15. Some of the most notable include : (i) the original notes of the agents differ materially from the 302s; (ii) there were material alterations to the 302s to set up the “false statements,” and (iii)
the government has extensive reports of Mr. Flynn’s briefings and debriefings on all his foreign contacts—including his Russia trip and his meeting with Turkish officials—giving lie yet again to the public pretext of the FBI “investigation” of Mr. Flynn. Further, what is still a heavily redacted 302 for former Agent Strzok, since January 2017, the government knew, but still has not disclosed the full statements and notes that show Deputy Attorney General Sally Yates said the interview of Mr. Flynn was “problematic,” and she was “unclear” why the FBI was investigating or interviewing Mr. Flynn at all.”

“12 Mr. McCabe pointed to Mr. Flynn’s “very public interactions with Vladimir Putin and other Russians.” These “interactions” seem to have arisen from the work of CIA/FBI operatives Stefan Halper and Joseph Mifsud, and bookings made by Mr. Flynn’s American speakers’ bureau,
Leading Authorities (which books engagements for countless former government officials and prominent people). Leading Authorities booked him for three events with “Russian connections”: one in Moscow for RT and two in Washington. All were well attended by prominent persons from
around the world because of the important issues discussed and the presence of other recognized experts on the programs. See Ex. 14; MTC 4, 16.

Mifsud was present at the RT dinner in Moscow, and it is his cell phones recently obtained by the government that are expected to confirm that he was working for “western intelligence.” Dkt. 124.

Stefan Halper is a known long-time operative for the CIA/FBI. He was paid exorbitant sums by the FBI/CIA/DOD through the Department of Defense Department’s Office of Net Assessment in 2016. His tasks seem to have included slandering Mr. Flynn with accusations of having an affair with a young professor (a British national of Russian descent) Flynn met at an official dinner
at Cambridge University when he was head of DIA in 2014. Flynn has requested the records of Col. James Baker because he was Halper’s “handler” in the Office of Net Assessment in the Pentagon, and ONA Director Baker regularly lunched with Washington Post Reporter David Ignatius. Baker is believed to be the person who illegally leaked the transcript of Mr. Flynn’s calls to Ignatius. The defense has requested the phone records of James Clapper to confirm his contacts with Washington Post reporter Ignatius—especially on January 10, 2017, when Clapper told Ignatius in words to the effect of “take the kill shot on Flynn.” It cannot escape mention that the press has long had transcripts of the Kislyak calls that the government has denied to the defense.
MTC 34, 35, 37.”

https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.129.0_1.pdf

 

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Butowsky v. Folkenflik NPR et al motion quotes attorney Sidney Powell in Flynn case, “FBI officials systematically tampered with records and hid exculpatory evidence”

Butowsky v. Folkenflik NPR et al motion quotes attorney Sidney Powell in Flynn case, “FBI officials systematically tampered with records and hid
exculpatory evidence”

“Instead of doing so, the government has continued to defy its
constitutional, ethical and legal obligations to this Court and to the defense, and to hide evidence that it knows exonerates Mr. Flynn. As is the essence of the problem here, instead of protecting its citizens, the “government” is protecting its own criminal conduct and operatives.”…Attorney Sidney Powell October 23, 2019

Mueller, as a matter of determined policy, omitted key steps which any honest investigator would undertake. He did not commission any forensic examination of the DNC servers. He did not interview Bill Binney. He did not interview Julian Assange. His failure to do any of those obvious things renders his report worthless.”…Craig Murray

“Fox News news analyst Ellen Ratner relayed information from Wikileaks founder Julian Assange to Texas businessman Ed Butowsky regarding Seth Rich’s role in transferring emails to Wikileaks, according to an amended lawsuit that I filed this morning on behalf of Mr. Butowsky.”…Attorney Ty Clevenge

 

From Edward Butowsky v. David Folkenflik, et al filed October 28, 2019.

PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO COMPEL
FEDERAL BUREAU OF INVESTIGATION TO COMPLY WITH
SUBPOENA DUCES TECUM

“A lot has happened in the short period since the Plaintiff filed his MOTION TO
COMPEL and the government filed the FEDERAL BUREAU OF INVESTIGATION’S RESPONSE IN OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL (Doc. No. 76) (hereinafter “FBI RESPONSE”). In a reply filed on October 24, 2019 in United States v. Michael T. Flynn,
Case No. 1:17-cr-00232-EGS (D.D.C.), attorney Sidney Powell laid out damning
evidence that high-ranking FBI officials systematically tampered with records and hid exculpatory evidence for the purpose of framing the defendant, retired General Mike Flynn. The reply itself is sealed, but Ms. Powell publicly posted a redacted version online, and the Plaintiff has attached a copy as Exhibit 1. The Plaintiff requests that the Court take judicial notice of that attachment or obtain a copy of the reply (and its exhibits) directly from the D.C. court.

As the Court is probably aware, the criminal charges against General Flynn are an integral part of the “Russia Collusion Hoax” outlined in the Plaintiff’s SECOND AMENDED COMPLAINT. See, e.g., Petr Svab, “Did Flynn Just Call Out Mueller on Under-the-Table Plea Deal?”, The Epoch Times, July 14, 2019 (https://www.theepochtimes.com/did-flynnjust-call-out-mueller-on-under-the-table-plea-deal_3001928.html). If the FBI is willing to conceal records and tamper with evidence in order to frame a highly-decorated former
military officer, all for the purpose of promoting and protecting a political hoax, then it should not be difficult to believe that the FBI would conceal records about Seth Rich in order to protect that same hoax.”

Read more:

https://www.courtlistener.com/recap/gov.uscourts.txed.183024/gov.uscourts.txed.183024.77.0.pdf

 

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John Brennan exposed by Citizen Journalists, Citizen Wells et al, March 2008 warnings on Obama Brennan, Brennan firm cauterized Obama passport file?

John Brennan exposed by Citizen Journalists, Citizen Wells et al, March 2008 warnings on Obama Brennan, Brennan firm cauterized Obama passport file?

“Vivek Kundra, who was tapped as the White House technology czar
March 5, oversaw technology projects and budgets for 86 D.C.
government agencies as head of the District’s Office of the Chief
Technology Officer.”
“Yusuf Acar, 40, who has worked in the technology office since
2004, was charged with bribery, conspiracy, money laundering and
conflict of interest.”
“Acar also told the informant that he could use computers to
create fake D.C. birth certificates, Hibarger said.”…Citizen Wells from pre rectified Washington Post article dated March 13, 2009

“Who benefited most from the suicide/murder of Orlando Jones?
Who benefited most from the murder of Donald Young?
Who benefited most from the murder of Lt. Quarles Harris Jr.?
Who benefited most from the suicide/murder of Christopher Kelly?
Who benefited most from the murder of Bill Gwatney?
Who benefited most from the death/murder of Andrew Breitbart?
And now
Loretta Fuddy?”…Citizen Wells

 

There are many reasons why John Brennan did not want Donald Trump elected.

Apparently he has been working hard behind the scenes to remove Trump.

Will he finally be prosecuted?

“The DOJ’s Russiagate Probe Just Turned Into A Criminal Investigation

What began as an administrative review by the Justice Department into the origins of Russiagate has “shifted” to a criminal inquiry, according to the New York Times, citing two people familiar with the matter.”

“And according to NBC NewsDurham has set his sights on former CIA Director John Brennan and former national intelligence director James Clapper.”

https://citizenwells.com/2019/10/25/john-durham-criminal-investigation-to-begin-power-to-subpoena-documents-and-witnesses-impanel-grand-jury-and-file-criminal-charges-brennan-clapper-focus/

 

From Citizen Wells March 21, 2008.

“I just received this comment and thought it worthy of highlighting.”

“Obama has a dual citizenship with Kenya. His passport was breached today by inquiring minds because Obama is an anti-Israel pro-pan-arabism Islamic-socialist who has ties to marxist Libyan president Muammar al Gadaffi, Syrian tycoon Antoin Rezko, Saudi Arabian sheikhs, and Rezko’s “close friend” 3.5 million money pal Auchi, the one who gave Obama fundraiser money: Iraqi billionaire global arms dealer Nadhmi Auchi”

“Marxist Nicaraguan President’s endorsement is for Obama, and he says: “It’s not to say that there is already a revolution under way in the U.S.; but yes, they [supporters of Barack Obama] are laying the foundations for a revolutionary change”

https://citizenwells.com/2008/03/21/barack-obama-passport-kenya-anti-israel-pro-arabism-islamic-socialist-rezko-auchi-saddam-hussein-odinga-marxist-black-panthers/

From Citizen Wells April 20, 2009.

“Obama’s top terrorism and intelligence adviser, John O. Brennan, heads a firm that was cited in March for breaching sensitive files in the State Department’s passport office, according to a State Department Inspector General’s report released this past July.”

“During a State Department briefing on March 21, 2008, McCormack confirmed that the contractor had accessed the passport files of presidential candidates Barack Obama, Hillary Rodham Clinton, and John McCain, and that the inspector general had launched an investigation.
Sources who tracked the investigation tell Newsmax that the main target of the breach was the Obama passport file, and that the contractor accessed the file in order to “cauterize” the records of potentially embarrassing information.”

https://citizenwells.com/2009/04/20/obama-birth-certificate-forgery-obama-corruption-vivek-kundra-yusuf-acar-forged-documents-john-brennan-passport-security-breach-long-form-birth-certificate-forgery/

The above segment was from a NewsMax article that has been scrubbed.

The new link to the NewsMax article:

https://www.newsmax.com/KenTimmerman/brennan-passport-breach/2009/01/12/id/337482/

Also from the NewsMax article, not reported at Citizen Wells earlier:

““They looked at the McCain and Clinton files as well to create confusion,” one knowledgeable source told Newsmax. “But this was basically an attempt to cauterize the Obama file.”

At the time of the breach, Brennan was working as an unpaid adviser to the Obama campaign.”

“Following the breach, State Department managers met with Senate Foreign Relations Committee Chairman Joseph Biden, whose committee has oversight over the Foreign Service and the passport office. Biden will be sworn in as Obama’s vice president on Jan. 20.

The State Department Office of Inspector General (OIG) issued a 104-page report on the breach last July. Although it is stamped “Sensitive but Unclassified,” the report was heavily redacted in the version released to the public, with page after page blacked out entirely.”

“Had Brennan been appointed CIA director, as rumored in the Obama campaign shortly after the election, senators also would have questioned him about an article he wrote in an obscure foreign policy magazine over the summer.

The article, entitled “The Conundrum of Iran: Strengthening Moderates without Acquiescing to Belligerence,” appeared in the July issue of “The Annals of the American Academy of Political and Social Science.”

Among other recommendations, it argued that the next U.S. administration should grant political legitimacy to the terrorist organizations Hezbollah and Hamas, and should exercise “strategic patience” with Iran rather than engaging in “bellicose” rhetoric and coercive diplomacy.”

“Key witness in passport fraud case fatally shot”

“A key witness in a federal probe into passport information stolen from the State Department was fatally shot in front of a District church, the Metropolitan Police Department said yesterday.

Lt. Quarles Harris Jr., 24, who had been cooperating with a federal investigators, was found late Thursday night slumped dead inside a car, in front of the Judah House Praise Baptist Church in Northeast, said Cmdr. Michael Anzallo, head of the department’s Criminal Investigations Division.”

Read more:

https://www.washingtontimes.com/news/2008/apr/19/key-witness-in-passport-fraud-case-fatally-shot/

 

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Carter Page v. US Department of Justice filed October 21, 2019, “The DOJ, its employees and officers…acted intentionally or willfully in violation of Dr. Page’s privacy rights,”

Carter Page v. US Department of Justice filed October 21, 2019, “The DOJ, its employees and officers…acted intentionally or willfully in violation of Dr. Page’s privacy rights,”

“Instead of doing so, the government has continued to defy its
constitutional, ethical and legal obligations to this Court and to the defense, and to hide evidence that it knows exonerates Mr. Flynn. As is the essence of the problem here, instead of protecting its citizens, the “government” is protecting its own criminal conduct and operatives.”…Attorney Sidney Powell October 23, 2019

Mueller, as a matter of determined policy, omitted key steps which any honest investigator would undertake. He did not commission any forensic examination of the DNC servers. He did not interview Bill Binney. He did not interview Julian Assange. His failure to do any of those obvious things renders his report worthless.”…Craig Murray

“McCabe had a role in crafting the “insurance policy” in the event Mr. Trump was elected.  Expect to find Comey a part of that also.”…Attorney Sydney Powell

 

From The Epoch Times.

“Carter Page Sues DOJ, Demands Review of IG Report Prior to Release

A former Trump campaign associate who was wiretapped by the FBI sued the Department of Justice (DOJ) on Oct. 21, demanding that the government provide him with the opportunity to review, before it is made public, the forthcoming inspector general’s report on potential surveillance abuses in his case.

In a lawsuit filed with the U.S. District Court in Washington, Carter Page accuses the DOJ of violating his privacy rights by failing to grant him the opportunity to review the report before the document is published.”

“Page additionally alleges that the DOJ violated his privacy rights by disclosing copies of the Foreign Intelligence Surveillance Act (FISA) application to the New York Times prior to giving him an opportunity to review the documents.

In addition to requesting damages and the prosecution of the officials involved, Page is asking the court to order the DOJ to hand over all of the documents he has long sought to review and amend.

“The DOJ, its employees and officers, including those in the affiliated agency of the FBI under their jurisdiction, acted intentionally or willfully in violation of Dr. Page’s privacy rights,” the lawsuit states.”

“The FBI obtained the warrant as part of its counterintelligence investigation of the Trump campaign. The application relies heavily on the dossier of political opposition research on then-candidate Donald Trump. Former British intelligence officer Christopher Steele compiled the dossier by paying second- and third-hand sources with ties to the Kremlin. The FISA warrant application fails to mention that the Hillary Clinton campaign and the Democratic National Committee paid for the dossier.”

Read more:

https://www.theepochtimes.com/carter-page-sues-doj-demands-ig-report-be-delayed-for-review_3128379.html

Read the lawsuit:

https://www.scribd.com/document/432130059/Carter-Page-v-DOJ

 

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Attorney General Barr: why are you not protecting key witness Julian Assange? Answer to Russian collusion hoax, Mueller deep state coverup

Attorney General Barr: why are you not protecting key witness Julian Assange? Answer to Russian collusion hoax, Mueller deep state coverup

“Instead of doing so, the government has continued to defy its
constitutional, ethical and legal obligations to this Court and to the defense, and to hide evidence that it knows exonerates Mr. Flynn. As is the essence of the problem here, instead of protecting its citizens, the “government” is protecting its own criminal conduct and operatives.”…Attorney Sidney Powell October 23, 2019

Mueller, as a matter of determined policy, omitted key steps which any honest investigator would undertake. He did not commission any forensic examination of the DNC servers. He did not interview Bill Binney. He did not interview Julian Assange. His failure to do any of those obvious things renders his report worthless.”…Craig Murray

“Fox News news analyst Ellen Ratner relayed information from Wikileaks founder Julian Assange to Texas businessman Ed Butowsky regarding Seth Rich’s role in transferring emails to Wikileaks, according to an amended lawsuit that I filed this morning on behalf of Mr. Butowsky.”…Attorney Ty Clevenge

 

Attorney General Barr:

Julian Assange is being persecuted in Belmarsh Prison.

He is being kept there by the deep state.

He has already stated that the Russians were not the source of the DNC leaks.

He knows the source of the leaks.

He is the key non government witness.

Ellen Ratner, sister of a former Assange attorney met with Julian Assange and he told her the leaks were done by an insider.

Allowing Assange to languish in prison, further deteriorate and possibly die is not only a human rights violation but another travesty in the Justice Department handling of cases.

John Durham has apparently begun a criminal prosecution.

Julian Assange’s safety should have already been secured.

Promise him immunity and release him now.

Wells

 

More here:

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Sidney Powell motion for Brady material and hold prosecutors in contempt meshes with Durham prosecution, October 24, 2019, Fake Russian collusion explained 101

Sidney Powell motion for Brady material and hold prosecutors in contempt meshes with Durham prosecution, October 24, 2019, Fake Russian collusion explained 101

“Instead of doing so, the government has continued to defy its
constitutional, ethical and legal obligations to this Court and to the defense, and to hide evidence that it knows exonerates Mr. Flynn. As is the essence of the problem here, instead of protecting its citizens, the “government” is protecting its own criminal conduct and operatives.”…Attorney Sidney Powell October 23, 2019

“Prosecutors Brandon Van Grack of the Justice Department’s national security division, who was formerly on Mr. Mueller’s team, and Assistant U.S. Attorney Deborah Curtis, of Washington, provided little explanation as to why they were not turning over the transcripts.”…Pittsburgh Post-Gazette June 1, 2019

“McCabe had a role in crafting the “insurance policy” in the event Mr. Trump was elected.  Expect to find Comey a part of that also.”…Attorney Sydney Powell

 

Attorney Sidney Powell, who knows the Justice Department inside and out, filed a motion yesterday, October 24, 2019, concurrently with the apparent start of prosecution by John Durham.

The contents of the motion could be considered an explanation into the fake Russian Collusion narrative, i.e. Justice Department corruption 101.

 

“FLYNN REPLY IN SUPPORT OF HIS MOTION TO COMPEL PRODUCTION OF BRADY MATERIAL AND TO HOLD THE PROSECUTORS IN CONTEMPT”

“TABLE OF CONTENTS
ARGUMENTS AND AUTHORITIES IN REPLY…………………………………………………………….. 3
A. The Government’s Suppression of the Actual Strzok-Page Texts Mandates a Finding of Contempt……………………………………………………………………………………………………………….. 5
1. “A Pretext to Interview Some People.” …………………………………………………………………. 6
2. “Many Meetings” to Strategize the Interview of Flynn………………………………………….. 7
3. “Off the Rails” ……………………………………………………………………………………………………. 8
4. The Plan Worked: Mr. Flynn was “Relaxed,” “Jocular,” and “Unguarded.”…………. 9
5. Reporting Back: Flynn’s “Demeanor Was Sure.”
He Was Telling the Truth or Believed He Was Telling the Truth…………………………….. 10
6. Agents Manipulate the Flynn 302……………………………………………………………………….. 10
7. February 14: “Launch f 302.”…………………………………………………………………………….. 11
8. The Media Leak Strategy with DOJ……………………………………………………………………. 12
9. The FBI Opens Obstruction Case on President Trump
and “Locks In” Case on “Flynn?”………………………………………………………………………….. 12
B. The FBI Knew Its Entire Investigation of Flynn Was A Pretext. ……………………………. 14
C. Brady Requires the Government to Produce Exculpatory Evidence in Time for the Defense to Use It. ……………………………………………………………………………………………………… 18
D. Full, Actual, Unredacted Documents, The Original 302, Drafts Prior to
February 10, 2019, and the 1A File and Subfiles Must be Produced Pursuant to Brady. 22
1. Agent Strzok’s notes do not appear to have been taken contemporaneously during the  Interview………………………………………………………………………………………………………….. 24
2. The 302 statement that Mr. Flynn was told the “nature of the interview” is false. … 25
3. Mr. Van Grack’s Productions of Flynn 302s Were Incomplete and Misleading. …… 25
4. The Final 302 Falsely States that Mr. Flynn Remembered Making Four to Five Calls from the Dominican Republic When Both Sets of Notes State He Does Not Remember.
………………………………………………………………………………………………………………………………
5. The Notes Provide No Support for a Chunk of the 302 That Purports to Provide a “Factual Basis” for the Plea. ………………………………………………………………………………….. 27
6. Mr. Flynn’s Statements Were Not Material. ……………………………………………………….. 27
7. The Flynn 302 Is Discussed in the Page-Strzok Texts and Was Not Approved by McCabe Until the Day After Flynn Resigned from the White House……………………….. 28
E. Classified Information Will Prove that Any Investigation of Mr. Flynn Was
Pretextual. ……………………………………………………………………………………………………………….. 28
1. Yunis Mandates Disclosure of The Classified Information Requested as Brady…….. 28
2. The DIA Reports of Briefing and Debriefings Belie Any Basis to Investigate Mr. Flynn and Likely Further Undermine the Factual Basis for the Plea……………………….. 29
3. The Letter from Sir Mark Lyall Grant to the Incoming National Security Team
Invalidates Any Use of Information from Christopher Steele, Further Undermines Any “Russia” Connection, and is Being Suppressed. ……………………………………………………… 30
CONCLUSION ……………………………………………………………………………………………………………. 32
CERTIFICATE OF SERVICE……………………………………………………………………………………… 33
Case 1:17-cr-00232-EGS Document 129”

“CONCLUSION
In its relentless pursuit of Mr. Flynn, the government became the architect of an injustice so egregious it is “repugnant to the American criminal system.” Russell, 411 U.S. at 428 (citations omitted). For these reasons and those in our original Motion and Brief in Support, this Court should compel the government to produce the evidence the defense requests in its full, unredacted
form. Given the clear and convincing evidence herein, this Court should issue an order to show cause why the prosecutors should not be held in contempt; and should dismiss the entire prosecution for outrageous government misconduct.”

https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.129.0_1.pdf

 

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