Tag Archives: 2020

Michael Flynn response to prosecution opposition to motion to dismiss Feb 18, 2020, “government’s response admits astounding and widespread government misconduct”

Michael Flynn response to prosecution opposition to motion to dismiss Feb 18, 2020, “government’s response admits astounding and widespread government misconduct”

“Immediately after President Trump won election, opponents inaugurated what they call ‘The Resistance’ and they rallied around an explicit strategy of using every tool and maneuver to sabotage the functioning of the executive branch.” …Attorney General Barr

“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

“The FBI clearly has records pertaining to Seth Rich, and it has withheld those
records in bad faith.”…Attorney Ty Clevenger October 11, 2019

 

From the Michael Flynn response to prosecution opposition to motion to dismiss February 18, 2020.

“The government’s February 12, 2020, response in opposition to Mr. Flynn’s Motion to Dismiss, ECF No. 169, demonstrates only its adamant refusal to recognize its obligations to seek justice not convictions and to produce evidence favorable to the defense under Brady v. Maryland, 373 U.S. 83 (1963). It continues to disregard this Court’s Brady order, which required it to produce
information favorable to the defense since December 2017.

Now, more than two years after this Court’s order—and more than one year after the “extended plea colloquy” on which the government repeatedly harps—the defense learned from a stunning report of the Inspector General (“IG Report”) that one of the two FBI agents, who broke all protocols to interview Mr. Flynn in the White House on January 24, 2017, was a surreptitious participant in a presidential briefing on August 17, 2016. The FBI assigned him specifically to
collect information from and about Mr. Flynn to give the FBI further advantage and insights in the agents’ plan to interview Mr. Flynn in the White House if Trump won the election. The IG Report revealed conduct of this agent and in the highest tiers of the FBI that is indeed “so grossly shocking and so outrageous as to violate the universal sense of justice.” United States v. Restrepo, 930 F.2d
705, 712 (9th Cir. 1991).

If the government and this Court fail to acknowledge it, then surely a court will find that this is the very case that mandates the exercise of a court’s supervisory power if not the constitutionally required application of Brady to dismiss this prosecution because of the government’s appalling and unrepentant attitude. Bank of Nova Scotia v. United States, 487 U.S. 250, 263 (1988); see Napue v. Illinois, 360 U.S. 264 (1959) (conviction obtained on known false
evidence cannot stand).”

“The government’s response admits astounding and widespread government misconduct as detailed in the IG Report regarding the Crossfire Hurricane investigation and FISA applications, yet Mr. Van Grack refuses to admit any impact on Mr. Flynn’s case. For these reasons and those in Mr. Flynn’s Motion to Dismiss and other briefs, the government’s outrageous misconduct
mandates dismissal of this prosecution with prejudice. Its opposition proves no interest in justice, defies credulity, and demonstrates the government’s reprehensible and unrepentant attitude toward the most serious of all issues that affect due process and the administration of justice.”

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https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.170.0_6.pdf

 

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Flynn prosecution response to Motion to Dismiss for Egregious Government Misconduct Feb 12, 2020, Why is Brandon Van Grack still assigned?

Flynn prosecution response to Motion to Dismiss for Egregious Government
Misconduct Feb 12, 2020, Why is Brandon Van Grack still assigned?

“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

“Why John Brennan, Peter Strzok and DOJ Needed Julian Assange Arrested”…The Conservative Treehouse November 3, 2019

“The FBI clearly has records pertaining to Seth Rich, and it has withheld those
records in bad faith.”…Attorney Ty Clevenger October 11, 2019

 

From the Flynn prosecution response to Motion to Dismiss for Egregious Government Misconduct Feb 12, 2020.

“The defendant does not identify government misconduct in this case, and certainly not conduct that is “outrageous” or “grossly shocking.” His allegations center on the OIG Report, see Mot. to Dismiss at 6-16, but the misconduct described in the Report does not pertain to the investigation of the defendant or his false statements to the FBI on January 24, 2017. And the information in the Report pertaining to SSA 1 does not constitute a Brady violation. Defendant’s
remaining allegations have either previously been rejected by this Court or are irrelevant to the charges to which defendant pleaded guilty.
a. The errors and/or misconduct described in the OIG Report do not pertain to defendant’s false statements to FBI on January 24, 2017.

The defendant was charged with and pleaded guilty to providing false statements to FBI agents during an interview on January 24, 2017. The OIG Report does not identify errors or misconduct pertaining to the investigation of the defendant.4
With respect to the investigation of the defendant, the OIG Report “concluded that the FBI had sufficient predication to open [a] full counterintelligence investigation [] of . . . Flynn . . . in August 2016.” OIG Report at 352. The
defendant’s motion focuses on SSA 1’s participation on August 17, 2016, in a strategic intelligence briefing given to then-candidate Trump and the defendant. As the OIG Report explained, the FBI selected SSA 1 to participate in that briefing “in part, because Flynn, who would be attending thebriefing with candidate Trump, was a subject of the ongoing investigations.” Id. at 407-08. The Report does not allege that SSA 1’s participation in the briefing amounted to misconduct. Rather, the Report concludes SSA 1’s participation was a “judgment call[] left to the discretion of FBI officials.” Id. at 408. And the decision for SSA 1 to participate was “reached by consensus” among “higher levels” at the FBI. Id. at 341-42, 408. 5

The OIG Report did identify instances where the FBI did not comply with existing policies and neglected to exercise appropriate diligence, which led to “significant errors or omissions” in the four FISA applications for surveillance targeting Carter Page. But those four FISAs did not target the defendant. To the contrary, the Report affirmed that the FBI “did not seek FISA
surveillance” of the defendant. Id. at 357 n.488. The government does not dispute the seriousness of the “significant errors and omissions” described in the Report. But the compliance and diligence failures and “significant errors” as they relate to the Page FISA applications do not warrant or necessitate the dismissal of the charge against the defendant. ”

Read more:

https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.169.0_7.pdf

Why has Attorney General Barr allowed Brandon Van Grack to remain on this case or even remain employed by the USDOJ?

 

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Seth Rich murder cover ups and misconduct by FBI, Ty Clevenger v. U.S. Department of Justice telehearing February 12, 2020, Caitlin Sinclair of One America News permission to listen

Seth Rich murder cover ups and misconduct by FBI, Ty Clevenger v. U.S. Department of Justice telehearing February 12, 2020, Caitlin Sinclair of One America News permission to listen

“The FBI clearly has records pertaining to Seth Rich, and it has withheld those
records in bad faith.”…Attorney Ty Clevenger October 11, 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

“Journalism is printing what someone else does not want printed: everything else is public relations.”…George Orwell

 

Filed by Attorney Ty Clevenger February 7, 2020.

“Re: Ty Clevenger v. U.S. Department of Justice, et al., Civil Action No. 18-
CV-01568 (WFK) (LB)
Judge Bloom:
Caitlin Sinclair, a reporter for One America News, told me she contacted your
chambers about listening to the telehearing scheduled for February 12, 2020 in the matter above, and she said she was informed by your clerk that one of the parties would need to request authorization on her behalf. I write to request such authorization.

The circumstances surrounding the murder of Seth Rich have been subject to
national media attention since late 2016, shortly after Mr. Rich was murdered. Likewise, misconduct and cover-ups within the FBI have been the subject of widespread media attention for at least two years. I believe the public and, by extension, the media have a legitimate interest in the February 12, 2020 hearing, therefore I request that Ms. Sinclair be permitted to listen to the telehearing.

I conferred with Asst. U.S. Attorney Kathleen Mahoney, counsel for the
Defendants, and she indicated that the Defendants take no position on this request. Thank you in advance for your consideration.”

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https://www.courtlistener.com/recap/gov.uscourts.nyed.414614/gov.uscourts.nyed.414614.54.0.pdf

 

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Joe Biden criminal complaint filed by Ukrainian prosecutor  Viktor Shokin January 28, 2020, “series of serious crimes committed by…managers of…Burisma Holding…board of directors…Hunter Biden”

Joe Biden criminal complaint filed by Ukrainian prosecutor  Viktor Shokin January 28, 2020, “series of serious crimes committed by…managers of…Burisma Holding…board of directors…Hunter Biden”

“Joe Biden “Outraged We Seized Burisma Assets”, Could No Longer Pay His Son…”…Former Ukraine Prosecutor Shokin

“One of the downstream consequences of Rudy Giuliani investigating the Ukraine corruption and money laundering operation to U.S. officials is that it ends up catching Senator Graham.”…Conservative Treehouse

“I discovered a pattern of corruption that the Washington press covered up for years! I’m also going to bring out a massive pay-for-play scheme under the Obama Administration that will devastate the Democrat Party. Do you honestly think I’m intimidated?”…Rudy Giuliani,

 

From Zero Hedge.

“Ukrainiain ‘Son Of A Bitch Who Got Fired’ Files Criminal Complaint Against Biden For Abuse Of Power

The Ukrainian prosecutor who Joe Biden bragged about getting fired, Viktor Shokin, has filed a criminal complaint in Kiev against the former Vice President for abusing his power, according to French news outlet Les Crises (confirmed by multiple sources according to PJ Media).

Shokin writes in his complaint:

During the period 2014-2016, the Prosecutor General’s Office of Ukraine was conducting a preliminary investigation into a series of serious crimes committed by the former Minister of Ecology of Ukraine Mykola Zlotchevsky and by the managers of the company “Burisma Holding Limited “(Cyprus), the board of directors of which included, among others, Hunter Biden, son of Joseph Biden, then vice-president of the United States of America.

The investigation into the above-mentioned crimes was carried out in strict accordance with Criminal Law and was under my personal control as the Prosecutor General of Ukraine.

Owing to my firm position on the above-mentioned cases regarding their prompt and objective investigation, which should have resulted in the arrest and the indictment of the guilty parties, Joseph Biden developed a firmly hostile attitude towards me which led him to express in private conversations with senior Ukrainian officials, as well as in his public speeches, a categorical request for my immediate dismissal from the post of Attorney General of Ukraine in exchange for the sum of US $ 1 billion in as a financial guarantee from the United States for the benefit of Ukraine.

* * *

Shokin says that due to “continued pressure from the Vice President of the United States Joseph Biden to oust me from the job by blackmailing the allocation of financial assistance, I, as the man who places the State interests above my personal interests, I agreed to abandon the post of Prosecutor General of Ukraine.“”

“In November, the State department released detailed accusations against the Bidens levied by Shokin and his successor, Yiury Lutsenko. In them, Shokin claims:”

“Shokin then details how in July 2015, “US Ambassador Geoffrey R. Pyatt told him that the investigation has to be handled with white gloves, which according to Mr. Shokin, that implied do nothing. On or about September 2015 Mr. Pyatt gave a speech in Odessa where he stated that the cases were not investigated correctly and that Mr. Shokin may be corrupt.”

“Mr. Shokin further stated that on February of 2016 warrants were placed on the accounts of multiple people in Ukraine. There were requests for information on Hunter Biden to which nothing was received.

“It is believed that Hunter Biden receives a salary, commission plus one million dollars.”

“President of Ukraine Petro Poroshenko [who Joe Biden threatened to withhold $1 billion in US loan guarantees] told Mr. Shokin not to investigate Burisma as it was not in the interest of Joe and/or Hunter BidenMr. Shokin was called into Mr. Poroshenko’s office and told that the investigation into Burisma and the Managing Director where Hunter Biden is on the board, has caused Joe Biden to hold up one billion dollars in US aid to Ukraine.

“Mr. Shokin stated that on or around April of 2016 Mr. Petro Poroshenko called him and told him he had to be fired as the aid to the Ukraine was being withheld by Joe Biden. Mr. Biden told Mr. Poroshenko that he had evidence that Mr. Shokin was corrupt and needed to be fired. Mr. Shokin was dismissed in April of 2016 and the US aid was delivered within one and one half months.”

“On a different point Mr. Shokin believes the current Ambassador Marie L. Yovanovitch denied his visa to travel to the US. Mr. Shokin stated that she is close to Mr. Biden. Mr. Shokin also stated that there were leaks by a person named Reshenko of the Ukrainian State Secret Service about the Manafort Black Book. Mr. Shokin stated that there is possible deceit in the Manafort Black Book.””

Read more:

https://www.zerohedge.com/political/ukrainiain-son-bitch-who-got-fired-files-criminal-complaint-against-biden-abuse-power

 

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Flynn motion to dismiss for egregious government misconduct January 29, 2020, Remarkable new Brady evidence prosecution has long suppressed

Flynn motion to dismiss for egregious government misconduct January 29, 2020, Remarkable new Brady evidence prosecution has long suppressed

And I’ve now found a witness who says the original 302 did in fact say that Flynn was honest with the agents.”...Attorney Sidney Powell

“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

“The FBI clearly has records pertaining to Seth Rich, and it has withheld those
records in bad faith.”…Attorney Ty Clevenger October 11, 2019

 

From the General Michael Flynn

MOTION TO DISMISS FOR EGREGIOUS GOVERNMENT
MISCONDUCT AND IN THE INTEREST OF JUSTICE

January 29, 2020.

“Michael T. Flynn (“Mr. Flynn”) hereby moves to dismiss the charges against him for outrageous government misconduct and in the interest of justice.1 This motion is based on exculpatory evidence (“Brady”) as well as egregious government misconduct that was discovered after Mr. Flynn’s Motion to Compel Brady Material (ECF No. 109) and related briefing.

Such exculpatory evidence and outrageous misconduct includes that on December 9, 2019, the Inspector General of the Department of Justice (“DOJ”) issued its 478-page report on the “Review of Four FISA Applications and Other Aspects of the FBI’s Crossfire Hurricane Investigation” (“IG Report”).2 The IG Report illustrates the misconduct by the government as further detailed below.

Further, on December 15, 2019, the government produced to Mr. Flynn’s defense team 637 pages of documents—including sixteen long-awaited FD-302s and 206 pages of corresponding FBI handwritten notes—all of interviews of Mr. Flynn. Additionally, in its Supplemental Sentencing Memorandum (which also breaches the plea agreement), the government included never-produced FD-302s of the government’s interviews with Mr. Flynn’s prior counsel at Covington & Burling (“Covington”), Robert Kelner and Brian Smith, from June 2018. ECF No. 150-4 through 150-6. The government also belatedly produced to Mr. Flynn FD-302s and related documents as recently as January 23, 2020. ECF No. 157.

These documents contain remarkable new Brady evidence that the prosecution has long suppressed. For instance, this evidence not only belies the bogus FARA “false statement” charges Mr. Van Grack leveraged against Covington and Mr. Flynn, but also demonstrates Mr. Van Grack knew these charges were bogus, yet sought to have Mr. Flynn make a false statement in his EDVA interview on June 25, 2019, and was encouraging subornation of perjury by Mr. Flynn. See ECF
No. 151. Additionally, the IG Report shows that the government long suppressed evidence of shocking malfeasance by the leadership of the FBI and Supervisory Special Agent 1 (“SSA 1”) that was favorable to Mr. Flynn’s defense. For these reasons, and those outlined in prior briefing, Mr. Flynn moves to dismiss this entire prosecution for outrageous government misconduct and in
the interest of justice.

This factually and legally baseless “investigation” and prosecution of Mr. Flynn has no precedent. From the FBI’s insertion of SSA 1 into the August 17, 2016 presidential briefing of candidate Trump and Mr. Flynn, to the former Director of the FBI bragging and laughing on national television about his own cleverness and violations of FBI/DOJ rules in dispatching agents to the White House to interview the new President’s National Security Advisor, to the still missing
original FBI FD-302 of the January 24, 2017 interview—everything about this prosecution has violated long-standing standards and policy for the FBI and the DOJ. In addition to the myriad of breaches and irregularities identified in our prior filings, the IG Report released on December 9, 2019, reveals even more evidence of the FBI’s deceitful and wrongful conduct that should have
been disclosed to Mr. Flynn’s defense.3

There were two FBI agents who interviewed Mr. Flynn in the White House on January 24, 2017—Agent Peter Strzok and SSA 1. The IG Report confirms both participated in government misconduct. As explained in further detail below, not only was Strzok so biased, calculated, and deceitful he had to be terminated from Mueller’s investigation and then the FBI/DOJ, but it has also now been revealed that SSA 1 was surreptitiously inserted in the mock presidential briefing
on August 17, 2016, to collect information and report on Mr. Trump and Mr. Flynn. Moreover, SSA 1 was involved in every aspect of the debacle that is Crossfire Hurricane and significant illegal surveillance resulting from it. Further, SSA 1 bore ultimate responsibility for four falsified applications to the FISA court and oversaw virtually every abuse inherent in Crossfire Hurricane—
including suppression of exculpatory evidence. See generally IG Report.

Only the dismissal of this prosecution in its entirety would begin to get the attention of the government, the FBI, and the DOJ needed to impress upon them the “reprehensible nature of its acts and omissions.” United States v. Kohring, 637 F.3d 895, 914 (9th Cir. 2011) (Fletcher, J., concurring in part and dissenting in part).”

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https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.162.0_1.pdf

 

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Unequivocal proof FBI hiding Seth Rich records, Attorney Ty Clevenger letter to US Attorney John Durham, Criminal Complaint January 27, 2020

Unequivocal proof FBI hiding Seth Rich records, Attorney Ty Clevenger letter to US Attorney John Durham, Criminal Complaint January 27, 2020

And I’ve now found a witness who says the original 302 did in fact say that Flynn was honest with the agents.”...Attorney Sidney Powell

“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

“The FBI clearly has records pertaining to Seth Rich, and it has withheld those
records in bad faith.”…Attorney Ty Clevenger October 11, 2019

 

From Attorney Ty Clevenger January 27, 2020.

“We now have unequivocal proof that the FBI is hiding records about Seth Rich

The FBI is hiding documents about murdered Democratic National Committee employee Seth Rich, according to emails released last week, so this morning I requested a criminal investigation into the cover-up.

As most people outside of solitary confinement know, the whole “Russian collusion” investigation began with the premise that Russia hacked the DNC, but considerable evidence suggests that the DNC emails were downloaded by someone inside the DNC — liike Mr. Rich — and then provided to Wikileaks.

Rather than re-invent the wheel, I’ve copied and pasted my letter to U.S. Attorney John Durham, U.S. Attorney Richard Donoghue, and Inspector General Michael Horowitz:

Mr. Durham, Mr. Donoghue and Mr. Horowitz:

I wish to file a criminal complaint regarding false statements made by FBI Section Chief David M. Hardy in two affidavits [click here and here] filed in the FOIA case identified above [i.e.Ty Clevenger v. U.S. Department of Justice, et al., Civil Action No. 18-CV-01568]. I requested FBI records pertaining to Seth Rich, who allegedly was the source of Democratic National Committee emails published by Wikileaks in 2016 (rather than Russian hackers). In the affidavits (attached to the email version of this letter), Mr. Hardy testified that his office conducted a reasonable search, and it found no responsive records.

New evidence proves otherwise, and it appears that Mr. Hardy has perpetrated a fraud on the court. Judicial Watch recently published documents that it obtained in response to a FOIA request for communications between former FBI agent Peter Strzok and former FBI attorney Lisa Page (https://www.judicialwatch.org/wp-content/uploads/2020/01/JW-v-DOJ-Strzok-Page-Prod-16-00154.pdf), and I would direct your attention to pages 123-125. In those pages, you will find a heavily-redacted email discussion regarding Mr. Rich.  Note that the header on those emails is “Seth Rich.”

I defy Mr. Hardy to provide an innocent explanation for his office’s failure to produce these emails, and I suspect the misconduct reaches far beyond my specific FOIA request. Several facts are worth noting:

* Mr. Hardy touts the reasonableness of relying on the FBI’s Central Records System (“CRS”), but note that CRS does not search the FBI email system. That sort of half-baked, designed-to-fail search methodology would never be tolerated in litigation among private parties, yet it appears to be standard operating procedure at the FBI. And note that when I asked the FBI to search its email systems, it arbitrarily refused.

* Mr. Hardy’s staff purportedly searched for “Seth Conrad Rich” but failed to search for “Seth Rich,” another tactic designed to exclude responsive records.

* According to Mr. Hardy’s affidavit, the only records indexed by CRS are those that are manually designated by FBI personnel. Undoubtedly, FBI personnel know that they can immunize their email communications from FOIA requests simply by omitting the subject matter from the CRS, because Mr. Hardy will subsequently declare (1) that a CRS search is sufficient and (2) there is no need to conduct an email search.

I have previously written to Mr. Durham regarding evidence that the FBI was hiding information about Mr. Rich, and I have attached a December 13, 2019 order issued in Butowsky v. Folkenflik, Case No. 4:18-cv-00442-ALM-CMC (E.D. Tex.). Please see pages 23-29 in particular. Finally, I have attached an October 8, 2019 reply in the FOIA case, and it notes a previous occasion wherein Mr. Hardy provided inaccurate information to a court.”

 

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http://lawflog.com/?p=2282

 

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Flynn supplemental sentencing memorandum January 22, 2020, “Mr. Flynn told the government the truth about every question it asked him”

Flynn supplemental sentencing memorandum January 22, 2020, “Mr. Flynn told the government the truth about every question it asked him”

“John Adams was right: “facts are stubborn things; and whatever may be our wishes, our inclinations, or the dictates of our passions, they cannot alter the state of facts and evidence.” The government tried to manufacture facts in the Rafiekian case and they thought they could strongarm Mr. Flynn into helping them through perjury. But they underestimated the will and courage
of Michael T. Flynn, a man that bravely and selflessly spent his life protecting his fellowAmericans. In considering the whole story of this man and his sacrifices, the Court should impose no more than a sentence of probation.”...Attorney Sidney Powell motion January 22, 2020

“And I’ve now found a witness who says the original 302 did in fact say that Flynn was honest with the agents.”...Attorney Sidney Powell

“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

 

From the General Michael Flynn supplemental sentencing memorandum January 22, 2020.

“This Court should swiftly reject the government’s brazen attempt to punish Mr. Flynn for refusing to compose rather than sing. 1 The reversal of its sentencing position is not only unjust, itis unlawful. If left unchecked, it will send a dangerous message to cooperators – give testimony consistent with the government’s theory of the case, regardless of veracity, or pay the price with
your freedom.

The government also continues its campaign to hold Mr. Flynn responsible for false statements in a FARA filing. It ignores the facts in its possession as well as the decision of another court. Any misstatements in the March 2017 FARA filing at issue were not the fault of Mr. Flynn. He gave his lawyers complete and accurate documents and information. Moreover, he did his part
to make sure any FARA filing was accurate. The FARA statements listed in the Statement of Offense (ECF No. 4) are either not false or not attributable to Mr. Flynn.2

Mr. Flynn dedicated his life to serving his country. While the defendants in other cases cited by the government were working to benefit themselves, Mr. Flynn wrote a blank check on his life and put himself in harm’s way for more than five years in foreign deployments and thirtythree years of service to protect all Americans. He has touched the lives of countless people in the
process, many of whom wrote letters to the Court on his behalf. For the reasons set forth in this supplemental memorandum and Mr. Flynn’s initial sentencing brief (ECF No. 50), Mr. Flynn should receive a sentence, if any, 3 of probation and community service.”

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https://www.courtlistener.com/recap/gov.uscourts.dcd.191592/gov.uscourts.dcd.191592.156.0_1.pdf

 

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