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General Flynn has moved to withdraw his guilty plea due to the "government's bad faith, vindictiveness, and breach of the plea agreement."
Prosecutors (Van Grack) knowingly sought to induce false statements from Flynn relating to his FARA registration.
"The prosecutors concocted the alleged 'false statements' (relating to FARA filing) by their own misrepresentations, deceit, and omissions."
Van Grack demanded "false testimony from Mr. Flynn about the alleged 'false statements' in the FARA filing - despite Flynn explaining how he learned things in "hindsight" in June 2018

cc @KerriKupecDOJ
After Flynn refused to lie for prosecutors (Van Grack), they retaliated by:

1) Reversing course and labeling Flynn a co-conspirator

2) Improperly contacted Flynn's son

3) Put Flynn's son on the witness list for intimidation purposes (never called as a witness)
"The govt's tactics in relation for Mr. Flynn's refusal to 'compose' for the prosecution is a due process violation that can and should be stopped dead in its tracks by this Court"
These parts are very important - the DOJ's allegations of guilt don't match up to the record.

Link to Exhibit #9:
https://www.scribd.com/document/442973399/US-v-Flynn-Exh-9
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