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  • United States District Court District of Columbia United States of America v. Michael T. Flynn, Defendant. Criminal Action No. 17-232-EGS

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    This document is a second supplemental motion to dismiss the case against Michael Flynn for egregious government misconduct. It states that the government produced a second batch of 11 pages of documents to the defense on April 29th relating to the case, including emails and text messages between Strzok and Page. The motion argues that these newly produced documents further support Flynn's original motion to dismiss the case due to government misconduct. It was filed and dated on April 30th by Flynn's legal counsel.

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    gov.uscourts.dcd.191592.189.0_1

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    This document is a second supplemental motion to dismiss the case against Michael Flynn for egregious government misconduct. It states that the government produced a second batch of 11 pages of documents to the defense on April 29th relating to the case, including emails and text messages between Strzok and Page. The motion argues that these newly produced documents further support Flynn's original motion to dismiss the case due to government misconduct. It was filed and dated on April 30th by Flynn's legal counsel.

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    12 views3 pages

    United States District Court District of Columbia United States of America v. Michael T. Flynn, Defendant. Criminal Action No. 17-232-EGS

    Uploaded by

    Виктор Виктория
    This document is a second supplemental motion to dismiss the case against Michael Flynn for egregious government misconduct. It states that the government produced a second batch of 11 pages of documents to the defense on April 29th relating to the case, including emails and text messages between Strzok and Page. The motion argues that these newly produced documents further support Flynn's original motion to dismiss the case due to government misconduct. It was filed and dated on April 30th by Flynn's legal counsel.

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    Case 1:17-cr-00232-EGS Document 189 Filed 04/30/20 Page 1 of 3

    UNITED STATES DISTRICT COURT


    DISTRICT OF COLUMBIA

    UNITED STATES OF AMERICA

    v.

    MICHAEL T. FLYNN, Criminal Action No. 17-232-EGS

    Defendant.

    SECOND SUPPLEMENT TO MOTION TO DISMISS


    FOR EGREGIOUS GOVERNMENT MISCONDUCT

    On April 29, 2020, the government produced to the defense a second tranche comprised of

    eleven pages, including emails and additional Strzok-Page text messages. See Brady v. Maryland,

    373 U.S. 83 (1963) and this Court’s standing order, ECF No. 10. The second production bears

    Bates labeled as DOJSCO – 700023465 through DOJSCO – 700023475. The government then

    produced to Mr. Flynn a redacted version of those documents, agreed as suitable for filing upon

    the public docket (“Redacted Production”). These documents further support Mr. Flynn’s Motion

    to Dismiss for Egregious Government Misconduct and in the Interest of Justice. ECF No. 162. The

    Redacted Production is attached in its entirety as Exhibit 1.

    Dated: April 30, 2020 Respectfully submitted,

    /s/ Jesse R. Binnall /s/ Sidney Powell


    Jesse R. Binnall Sidney Powell
    Lindsay R. McKasson Molly McCann
    Harvey & Binnall, PLLC Sidney Powell, P.C.
    717 King Street, Suite 300 2911 Turtle Creek Blvd.,
    Alexandria, VA 22314 Suite 300
    Tel: (703) 888-1943 Dallas, Texas 75219
    Fax: (703) 888-1930 Tel: 214-707-1775

    1
    Case 1:17-cr-00232-EGS Document 189 Filed 04/30/20 Page 2 of 3

    [email protected] [email protected]
    [email protected] Admitted Pro Hac Vice
    Admitted Pro Hac Vice [email protected]
    Admitted Pro Hac Vice
    W. William Hodes
    The William Hodes Law Firm
    3658 Conservation Trail
    The Villages, Florida 32162
    Tel: (352) 399-0531
    Fax: (352) 240-3489
    Admitted Pro Hac Vice

    2
    Case 1:17-cr-00232-EGS Document 189 Filed 04/30/20 Page 3 of 3

    CERTIFICATE OF SERVICE

    I hereby certify that on April 30, 2020 a true and genuine copy of this Second Supplement

    to Motion to Dismiss for Egregious Government Misconduct and in the Interest of Justice was

    served via electronic mail by the Court’s CM/ECF system to all counsel of record, including:

    Timothy J. Shea, U.S. Attorney for the District of Columbia


    Brandon L. Van Grack, Special Assistant U.S. Attorney
    Jocelyn Ballantine, Assistant U.S. Attorney
    555 4th Street, NW
    Washington, D.C. 20530

    Respectfully submitted,

    /s/ Jesse R. Binnall


    Jesse R. Binnall, VSB# 79272
    HARVEY & BINNALL, PLLC
    717 King Street, Suite 300
    Alexandria, VA 22314
    Tel: (703) 888-1943
    Fax: (703) 888-1930
    [email protected]

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