1/Off top of my head--here's a primer on why all 302s, including early drafts tracking changes, were important to defense of Flynn. Keep in mind that most/nearly all Fed. Judges do not require production of Brady prior to defendant being charged. Sullivan is nearly alone on this.

2/Non trial-lawyers--and even trial lawyers who don't do federal criminal work--likely don't understand that the 302 document almost NEVER gets introduced into evidence at trial. The jury never gets to read it unless BOTH parties agree to submit it, and that almost never happens.

3/The reason production is battled-over--especially in a "False Statements" case--is because they form the foundation, AND BOUNDARIES, of what the FBI agent is going to testify about when attempting to establish that the defendant lied to the agents during the interview.

4/Proving a "false statement" case involves first establishing the circumstances of the interview, the specific subjects discussed, why those subjects were important, the specific questions asked, and the specific answers given by the defendant to those questions.

5/Once the specifics of the questions and the specifics of the answers are established in the trial record, the prosecution will then turn to proving that the answers given were 1) false, and 2) known to be false by the defendant when given during the interview.

6/Failures to provide information in response to questions can be a "False Statement" but is more difficult to prove because the gov't must show that the failure was intended to "conceal" that information from the investigators. This is why the agents used Flynn's own words...

7/...when they asked him about certain topics and Flynn's response was that he didn't discuss the topic with Kislyak. A good example of that is Flynn's denial that he discussed Russia "holding off" any retaliation after Obama expelled 35 suspected Russian intelligence agents.

8/But the various iterations of the 302 are important because they reflect NOT FLYNN'S thought processes, but the through processes of the Agents when they were drafting their report based on their recollections and notes of what Flynn said.

9/Every change made invites a question as to "Why?", and every answer to the "Why" question potentially opens up more inquiry into the Agents' thinking. When all the Defense has are the Agents' words reflected in the 302, the Agents' choice of words becomes the avenue of attack.

10/The Agent is going to have to answer questions about "Why" he chose to reflect the Def's answers to questions in a certain manner. Where the Agent's notes reflect only "short hand", and there are no phrases included with "quotes" around them, any "quotes" in the 302 are ripe.

11/ When the Agent testifies the "quote" is from his "memory", then you ask Agent to quote "What was my client's sentence to you immediately before the quoted sentence you wrote in the 302? What was his sentence to you immediately after what you wrote as a quote in the 302?"

12/This is important in Flynn's case because the Agents wrote in their 302 that Flynn did not appear to be deceptive in answering their questions. They would have to repeat that -- probably several times throughout an effective cross-exam.

13/ No witness not in the room for the interview would be allowed to take the stand an offer a different view. Such testimony would be uninformed opinion. From the Agents it would be a lay opinion based on their first-hand observations informed by their experience and training.

14/All the changes made to the 302 -- some of which SEEM to point towards efforts to make Flynn's responses appear to be more definitive and less equivocal -- would be explored against his backdrop of their view that he wasn't being deceptive when answering.

15/ "So what happened when you got back to your office, met with various officials [three briefings that same day] and expressed your views that he didn't seem deceptive even though his answers were inaccurate?? Were you met by opposite views from others who weren't there?"

16/"So in the next several days when you sat down to write, edit, rewrite, circulate for review, etc., your draft 302 of the interview, you allowed the POV of others that Flynn was knowingly lying to you to overcome your own view that he was not being deceptive as you stated?"

17/ "Wasn't it that desire to meet everyone else's views and "needs" from the 302 that resulted in it taking you nearly 15 days to craft a document that by FBI policy you had only 5 days to write??"

18/ The fact that all those lines of inquiry about the steps IN BETWEEN the interview and the signing of the 302, were unknown to the Def without production of all 302s, shows why not having produced them under Sullivan's Brady order, is a huge problem.

19/ A Def does not beat the Govt on a "false statement" case by proving his statements were actually true. Rather, a Def beats a "false statement" case by undermining the jury's confidence in the process by which the Gov't obtained the statements and presents them at trial.

20/ The Gov't has the burden of proof. Did the Gov't prove beyond a reasonable doubt what the Def. actually said in the interview? Has the process used by the Gov't to memorialize in its reporting what they claim the Def. said stood up to scrutiny?

21/ Are there motives in play which encouraged or promoted the "slanting" of what the Def actually said just a bit so that the case to be made is more simple and straightforward? Who had such motives, and why didn't they testify and be cross-examined on their involvement?

22/ And the coup de grace -- "What's the government hiding from you the jurors?"

23/ An attack on the process of proving guilt is almost always a more effective defense than an effort to prove factual innocence. The system is designed to work in this manner. Before the gov't can send someone to jail, their case MUST withstand stress and scrutiny.

24/ Under Sullivan's order, the Flynn was entitled to the information from which his attorneys could strategize whether there was an avenue of approach they could take towards the interviewing agents to undermine what their anticipated testimony was going to be.

25/ All the versions of the 302 were necessary to do that analysis -- not just the "Final" one which didn't reveal the "road-map" of thinking, and the actors involved, that went into it's production.