Michael Flynn Sentencing Memo

Case 1:17-cr-00232-EGS Document 50 Filed 12/11/18 Page 1 of 178
UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA
v.
Crim No.: 17-232 (EGS)
MICHAEL T. FLYNN,
Defendant
DEFENDANT’S MEMORANDUM IN AID OF SENTENCING
Robert K. Kelner
Stephen P. Anthony
Covington & Burling LLP
One CityCenter
850 Tenth Street, NW
Washington, DC 20001
Counsel for the Defendant
December 11, 2018

TABLE OF CONTENTS
I. A Sentence of Probation Is Warranted In Light of the 18 U.S.C. § 3553(a)

Factors ................................................................................................................................ 1
A. The History and Characteristics of the Defendant ............................................ 2
B. The Nature and Circumstances of the Offense .................................................. 7
C. The Seriousness of the Offense, Just Punishment, and Respect for the
Law ......................................................................................................................... 9
II. The Nature and Extent of General Flynn’s Cooperation ............................................ 12
III. Conclusion ....................................................................................................................... 13
ii
INDEX OF EXHIBITS
Letters of Support
A1. Frank Larkin, former U.S. Senate Sergeant-At-Arms
A2. Clare Eckert, on behalf of Flynn siblings
A3. General Jack Keane (Ret.), former Vice Chief of Staff, U.S. Army
A4. Colonel Yvette Hopkins (Ret.), U.S. Army
A5. Captain Seth Walters, U.S. Navy
A6. John Bucklew, United States Southern Command
A7. Kris Hager, Gold Star father
A8. Herber Felix, Deputy Assistant Chief Of Staff, G2 (Support) of the XVIII Airborne
Corps, U.S. Army
A9. Joe Flynn, brother
A10. Chief Master Sergeant Rod Hartsook (Ret.), U.S. Air Force
A11. Chief Master Sergeant Troy Eden (Ret.), U.S. Air Force
A12. Katherine Velez, Civilian Officer, Department of Defense
A13. Colonel Thomas Heaney (Ret.), U.S. Army
A14. Admiral Paul Becker (Ret.), Rear Admiral, U.S. Navy
A15. Rosalinda Ortega Pemberton, former Executive Assistant
A16. Nancy Walters, Army spouse and family friend
A17. Colonel Christopher Vanek, U.S. Army
A18. Margaret McDeed, Army spouse and family friend
A19. Lt. Colonel Scott McDeed (Ret.), U.S. Army
A20. Colonel Tom Faust (Ret.), U.S. Army
A21. Patricia O’Connell, Army spouse and family friend
iii
A22. Marian Elmore, Vice President of McJunkin Family Charitable Foundation
A23. Patricia Houchens and Ken Jones, President and Vice President of McJunkin Family
Charitable Foundation
A24. Major General Robert Walters, U.S. Army
A25. Paula Beckman, Army spouse and family friend
A26. Master Sergeant William Beckman (Ret.), U.S. Army
A27. Kimberly Becker, Navy spouse and family friend
A28. George Andrade, brother-in-law
A29. Elizabeth MacPherson, Army spouse and family friend
A30. Colonel Joseph Blair (Ret.), U.S. Army
A31. Cheryl Quinn, cousin-in-law
A32. Colonel Sharon Hamilton (Ret.), U.S. Army
A33. Captain Agustin Taveras (Ret.), U.S. Army
A34. Colonel Rey Velez (Ret.), U.S. Army
A35. Colonel Nichoel Brooks, U.S. Army
A36. Colonel Benjamin Clark (Ret.), U.S. Army
A37. John MacPherson, family friend
A38. Barbara Ledeen, family friend
A39. Sergeant Steven Kallemeyn (Ret.), U.S. Marine Corps
A40. Colonel Lawrence Connell (Ret.), U.S. Army and childhood friend
A41. Lt. Commander Harrison Coleman, U.S. Navy and former Aide-de-Camp
A42. Colonel Andres Nazario, U.S. Air Force
iv
A43. Captain Rick Myllenbeck (Ret.), U.S. Navy and former Aide-de-Camp
A44. Colonel Joseph Cox (Ret.), U.S. Army
A45. Colonel James Waurishuk (Ret.), U.S. Air Force
A46. Major Harry Hurst (Ret.), U.S. Army
A47. Lyndon Searles, Civilian Officer, Department of Defense
A48. Colonel Anthony MacDonald (Ret.), U.S. Army
A49. Lt. Colonel Michael Herbert (Ret.), U.S. Army
A50. Colonel Timothy Kiely (Ret.), U.S. Army
Military Service Materials
B1. Form DD-214
B2. 2004 Legion of Merit Citation
B3. December 1988 Army Evaluation
B4. April 1997 Army Evaluation
B5. September 1997 Army Evaluation
B6. April 2007 Army Evaluation
B7. 2002 Bronze Star Citation
v
PRELIMINARY STATEMENT
The defendant, through his attorneys, submits this Memorandum in Aid of Sentencing
and respectfully requests that the Court grant the Government’s Motion for Downward Departure
pursuant to § 5K1.1 of the United States Sentencing Guidelines, and sentence him to a term of
probation not to exceed one year, with minimal conditions of supervision, along with 200 hours
of community service. General Flynn has accepted responsibility for his conduct. He has
cooperated extensively with several Department of Justice investigations, as detailed in the
addendum to the Government’s Memorandum in Aid of Sentencing. As the Government has
made clear, his cooperation was not grudging or delayed. Rather, it preceded his guilty plea or
any threatened indictment and began very shortly after he was first contacted for assistance by
the Special Counsel’s Office. Following extraordinary public service in the United States Army,
during which his innovations as a highly decorated intelligence officer saved countless American
lives, and a lifetime of faithful devotion to his family and fellow service members and veterans,
as described in the powerful letters of support that accompany this submission, a sentence of
non-incarceration is both appropriate and warranted.
I. A Sentence of Probation Is Warranted In Light of the 18 U.S.C. § 3553(a) Factors
Viewed against the backdrop of the many cases that have come before this Court over the
years, General Flynn’s case stands out in several respects: his exceptional record of military
service; his genuine contrition for the uncharacteristic error in judgment that brought him before
this Court; and his deep respect for the law, as reflected in his extensive cooperation with the
Government’s efforts to get to the truth and to enforce the laws.
The federal sentencing statute requires that the Court tailor an individualized sentence
that is “sufficient, but not greater than necessary” to comply with the purpose of 18 U.S.C.
§ 3553(a)(2), and, in “determining the particular sentence to be imposed, shall consider—

1
(1) the nature and circumstances of the offense and the history and
characteristics of the defendant;
(2) the need for the sentence imposed—
(A) to reflect the seriousness of the offense, to promote respect for the
law, and to provide just punishment for the offense;
(B) to afford adequate deterrence to criminal conduct;
(C) to protect the public from further crimes of the defendant; and
(D) to provide the defendant with needed educational or vocational
training, medical care, or other correctional treatment in the most
effective manner.
18 U.S.C. § 3553(a). In this case, a sentence of probation is just and appropriate, for the reasons
stated below.
A. The History and Characteristics of the Defendant
General Flynn has dedicated nearly his entire adult life to the United States Army,
serving for 33 years and four months. He spent five of those years in combat in Grenada, Haiti,
Iraq, and Afghanistan, putting himself in harm’s way and spending long periods far from his
family. 1
Prior to his military career, General Flynn grew up in modest, working class
circumstances, in a tight-knit family of nine siblings living in a small house in Rhode Island, the
son of a career Army non-commissioned officer and a mother who, after raising a large family,
graduated from law school at the age of 63. His parents raised two sons who would go on to be
U.S. Army generals, along with other siblings who became CEOs and schoolteachers. He
worked as a lifeguard as a teenager, graduated from the ROTC program at the University of
Rhode Island, and then joined the regular Army. As a young intelligence officer deployed to
Grenada during the U.S. invasion of that island nation in 1983, he spotted two U.S. servicemen
1
See Form DD-214 (Ex. B1); Presentence Investigation Report (“PSR”) ¶ 70, United States v.
Flynn, 17 CR 232 (D.D.C. Nov. 20, 2018) (Doc. 45).
2
being swept out to sea. Drawing on his lifeguarding experience from the Rhode Island beaches,
he promptly dove off a 40-foot cliff into the ocean and rescued each of the servicemen,
swimming them back to shore one-by-one. 2 Though a celebrated story among his Army buddies
and family, it was not the only time he saved a life, both in the military and as a civilian. 3
Even in a military that tends to favor academy graduates, he rose steadily through the
ranks by virtue of his skill as an intelligence officer and his recognized talent for leadership,
ultimately serving in many of the Army’s key staff and command positions for intelligence. He
served for 16 years as a paratrooper, including in the 82nd Airborne Division, and qualified as an
elite U.S. Army Ranger, making more than 150 combat training jumps during the course of his
career. He eventually served as the senior intelligence officer for the 82nd Airborne Division and
for the 18th Airborne Corps; Director of Intelligence for U.S. Forces in Afghanistan (in 2002 and
again in 2009-10); Director of Intelligence for the Joint Special Operations Command, including
service in Iraq and Afghanistan; Director of Intelligence for the U.S. Central Command; Director
of Intelligence for the Joint Chiefs of Staff; Assistant Director of National Intelligence, in the
Office of the Director of National Intelligence; and finally, Director of the Defense Intelligence
Agency.
In recognition of his most significant accomplishments in the military, he was awarded,
on multiple occasions, the following decorations, among others:
• The Army Commendation Medal (1983, 1984, 1990, 1991, 1996)
• The Meritorious Service Medal (1982, 1987, 1992, 1995, 1997, 2000)
2
Letter of Support from Clare Eckert at 5 (Ex. A2).
3
As a teenager, he was recognized in his hometown for saving the lives of two children, whom
he and a friend pulled from the path of a rolling car, resulting in a commendation from the
Mayor. See id. at 2.
3
• The Joint Service Commendation Medal (1995)
• The Legion of Merit (2002, 2004)
• The Bronze Star (2002, 2005, 2006, 2007)
• The Defense Superior Service Medal (2007, 2008, 2009, 2010)
• The Defense Distinguished Service Medal (2014) 4
Citations accompanying these many awards and decorations tell a story of valor and
accomplishment on the battlefield that, for example, helped turn the tide of battle in Iraq. The
citation for one of his four Bronze Stars received for his service in Afghanistan recounts how he
“reorganized multiple joint and combined intelligence teams and processes to produce a dramatic
economy of force while intelligently leveraging and focusing collection assets against the
enemy.... His performance of duty in a combat zone reflects great credit upon him....” 5
Four-star General Jack Keane (Ret.), who at that time oversaw operations in Iraq and
Afghanistan as Vice Chief of Staff of the U.S. Army, writes in his attached letter of support that
General Flynn was “the officer who single-handedly changed how we created, processed, and
used intelligence during combat in the 9/11 wars.” General Keane describes General Flynn as a
“change agent and innovator,” adding that –
by sheer force of persuasion, uncommon good judgment and moral

courage, he changed the US operational and tactical intelligence
system, making it responsive to our warfighters. At their fingertips
was valuable information from data mining, photographs of
suspected terrorists, behavior patterns of enemy leaders and their
organizations, transcripts of phone conversations and terrorist email
exchanges. There is no doubt that Mike's contribution was
consequential to mission success and the preservation of life. 6
4
See Form DD-214 (Ex. B1); PSR ¶ 71.
5
2002 Bronze Star citation (Ex. B7).
6
Letter of Support from General Jack Keane at 2 (Ex. A3).
4
This tells an important part of General Flynn’s story, but the soldiers who fought
alongside him, as well as his commanders, emphasize the personal qualities that set him apart
from other general officers. They call him a “Soldier’s Soldier” because of his genuine devotion
to his troops, 7 describing him as a “caring” leader, a “mentor,” and a man who demonstrated
“sincere” and “selfless” commitment to his country. 8 He showed compassion not only for the
soldiers under his command, but also for their families. As both a Captain and Lieutenant
Colonel, he created care programs for service members and their families. 9 Colonel Tom Faust
(Ret.) recalls that “Mike Flynn was superb at creating a more family-friendly construct for his
Soldiers and their families,” and “[h]e and his wife, Lori, raised a tremendous Army Family and
provided an example of balance and teamwork that became an example for others to adopt and to
use across the Army.” 10
General Flynn served in Iraq from July 16, 2004 until June 15, 2007. 11 According to
those who served with him in the Joint Special Operations Command in Iraq, he demonstrated
7
Letter of Support from Thomas Heaney at 2 (Ex. A13).
8
Letter of Support from Anthony MacDonald at 1 (Ex. A48) (describing General Flynn’s
“outstanding leadership, selfless commitment, and unwavering loyalty”); Letter of Support from
Tom Faust at 4 (Ex. A20) (“[Mike] led, trained, mentored, coached, and protected thousands to
success….” ); 2004 Legion of Merit Citation (Ex. B2) (“He executed all missions with sincere
passion and dedication to duty and country”); December 1988 Army Evaluation at 2 (Ex. B3)
(“CPT Flynn has established a command climate based on active command presence, caring
leadership….” ); April 1997 Army Evaluation at 2 (Ex. B4) (“Mike is…a [t]remendous leader,
trainer and mentor….” ).
9
September 1997 Army Evaluation at 2 (Ex. B5) (“[Mike Flynn is] [a] truly concerned and
natural leader, Mike’s soldier and family care programs have made a believer out of his
troopers.”); December 1988 Army Evaluation at 2 (Ex. B3) (“CPT Flynn has established a
command climate based on active command presence, caring leadership, concern for the soldier's
family, and by establishing high standards of discipline in every activity.”).
10
Letter of Support from Tom Faust at 2 (Ex. A20).
11
Form DD-214 (Ex. B1).
5
selflessness and bravery. 12 In the Army’s 2007 formal evaluation of General Flynn, his
commanding officer, General Stanley McChrystal, lauded General Flynn’s actions during this
period, noting that “Mike Flynn’s impact on the nation’s War on Terror probably trumps any
other single person as his energy and skill at harnessing the Intelligence Community into a
focused effort was literally historic.” 13
While General Flynn is profoundly grateful for the opportunity to have served the United
States, his service did involve personal sacrifice. The years he spent on combat tours required
separation from his wife Lori, the high school sweetheart to whom he has been married for thirty
seven-years, and his two children, Matthew and Michael Jr. He missed countless moments with
his family, including birthdays, weddings, and anniversaries. General Flynn’s military service,
including in combat zones, also resulted in serious, chronic health issues detailed in the
Presentence Investigation Report, to which we direct the Court’s attention. 14
Following his retirement from the Army, General Flynn served those less fortunate than
himself in the communities where he has lived and worked. This service has continued during
the pendency of this case. 15 He works with the Special Operations Warrior Foundation and
Operation 300 to raise money for college scholarships and educational counseling for the
surviving children of Special Operations personnel killed in the line of duty, and the McJunkin
Family Charitable Foundation, which provides funding for veterans-related issues. 16 He is also
12
See Letter of Support from John Bucklew at 1 (Ex. A6); Letter of Support from Anthony
MacDonald at 1 (Ex. A48).
13
April 2007 Army Evaluation at 2 (Ex. B6).
14
See PSR ¶¶ 49-53.
15
Letter of Support from Rod Hartsook at 2 (Ex. A10); Letter of Support from Marian Elmore
at 1 (Ex. A22); Letter of Support from Patricia Houchens and Ken Jones at 1 (Ex. A23).
16
Id.
6
heavily involved in providing support for Gold Star Families who have lost a loved one in
combat. 17 As former Sergeant at Arms of the U.S. Senate, Frank Larkin, a Gold Star parent, put
it, General Flynn “devotes a considerable amount of his time advocating for Gold Star Families
whose loved ones made the ultimate sacrifice for this nation.... Mike Flynn will passionately roll
up his sleeves and lean forward to make a measurable difference in the lives of many veterans in
need.” 18
Finally, General Flynn and his family are very active in their local Catholic communities
at St. Mary’s and Jesus Savior Churches in Newport, Rhode Island. Many of the churches’
parishioners and priests have known General Flynn for decades and have shared memories with
him, both joyful and tragic. His Catholic faith and these communities remain an integral part of
his life. General Flynn’s commitment to community service, especially with respect to military
families and veterans, spans his lifetime, and he would welcome the opportunity to continue to
expand that community service.
B. The Nature and Circumstances of the Offense
General Flynn does not take issue with the description of the nature and circumstances of
the offense contained in the Government’s sentencing memorandum and the Presentence
Investigation Report. See Government’s Memorandum in Aid of Sentencing (“Gov. Sent.
Mem.”) at 2-5, United States v. Flynn, 17 CR 232 (D.D.C. Dec. 4, 2018) (Doc. 46); PSR ¶¶ 15-
22. As General Flynn has frankly acknowledged in his own words, he recognizes that his actions
were wrong and he accepts full responsibility for them. 19 There are, at the same time, some
17
Letter of Support from Kris Hager at 1 (Ex. A7); Letter of Support from Frank Larkin at 2 (Ex.
A1).
18
Letter of Support from Frank Larkin at 2 (Ex. A1).
19
See PSR ¶ 7.
7
additional facts regarding the circumstances of the FBI interview of General Flynn on January
24, 2017, that are relevant to the Court’s consideration of a just punishment.
At 12:35 p.m. on January 24, 2017, the first Tuesday after the presidential inauguration,
General Flynn received a phone call from then-Deputy Director of the FBI, Andrew McCabe, on
a secure phone in his office in the West Wing. 20 General Flynn had for many years been
accustomed to working in cooperation with the FBI on matters of national security. He and Mr.
McCabe briefly discussed a security training session the FBI had recently conducted at the White
House before Mr. McCabe, by his own account, stated that he “felt that we needed to have two
of our agents sit down” with General Flynn to talk about his communications with Russian
representatives. 21
Mr. McCabe’s account states: “I explained that I thought the quickest way to get this
done was to have a conversation between [General Flynn] and the agents only. I further stated
that if LTG Flynn wished to include anyone else in the meeting, like the White House Counsel
for instance, that I would need to involve the Department of Justice. [General Flynn] stated that
this would not be necessary and agreed to meet with the agents without any additional
participants.” 22
20
Certain information summarized or quoted in this Memorandum derives from documents
furnished to Defendant’s counsel pursuant to the Protective Order, United States v. Flynn, 17 CR
232 (D.D.C. Feb. 21, 2018) (Doc. 22). Undersigned counsel conferred with the Government,
which represented that disclosing the selected information does not constitute a violation of the
Protective Order.
21
Memorandum dated Jan. 24, 2017.
22
Id.
8
Less than two hours later, at 2:15 p.m., FBI Deputy Assistant Director Peter Strzok and a
second FBI agent arrived at the White House to interview General Flynn. 23 By the agents’
account, General Flynn was “relaxed and jocular” and offered to give the agents “a little tour” of
the area around his West Wing office. 24 The agents did not provide General Flynn with a
warning of the penalties for making a false statement under 18 U.S.C. § 1001 before, during, or
after the interview. Prior to the FBI’s interview of General Flynn, Mr. McCabe and other FBI
officials “decided the agents would not warn Flynn that it was a crime to lie during an FBI
interview because they wanted Flynn to be relaxed, and they were concerned that giving the
warnings might adversely affect the rapport,” one of the agents reported. 25 Before the interview,
FBI officials had also decided that, if “Flynn said he did not remember something they knew he
said, they would use the exact words Flynn used, . . . to try to refresh his recollection. If Flynn
still would not confirm what he said, . . . they would not confront him or talk him through it.” 26
One of the agents reported that General Flynn was “unguarded” during the interview and “clearly
saw the FBI agents as allies.” 27
C. The Seriousness of the Offense, Just Punishment, and Respect for the Law
While General Flynn has fully acknowledged his wrongful conduct and comes before the
Court to accept the consequences, the circumstances described above warrant the Court’s
consideration as it evaluates the seriousness of the offense, relative to the circumstances of
23
FD-302 dated Aug. 22, 2017, at 3.
24
Id.
25
Id.
26
Id.
27
Id.
9
witness interviews in typical cases charged under 18 U.S.C. § 1001, including the two cases
prosecuted by the Special Counsel that are discussed below.
General Flynn’s respect for the law is demonstrated by his decision to accept
responsibility for his actions soon after the Special Counsel’s Office reached out to him and
sought his cooperation. Even when circumstances later came to light that prompted extensive
public debate about the investigation of General Flynn, including revelations that certain FBI
officials involved in the January 24 interview of General Flynn were themselves being
investigated for misconduct, General Flynn did not back away from accepting responsibility for
his actions.
A term of probation with minimal conditions of supervision is a just punishment. 28 We
have identified thirteen cases over the past ten years that have proceeded to sentencing in the
U.S. District Court for the District of Columbia involving a violation of 18 U.S.C. § 1001 in
which the total offense level was 4, as it is in this case. 29 Only two of those thirteen cases
28
We ask the Court to exercise its discretion by deleting conditions 2, 3, 6, and 7 of the standard
conditions recommended under U.S.S.G. § 5B1.3(c). We also request that the Court conclude
based on the Presentence Investigation Report that drug testing is not necessary, in accordance
with U.S.S.G. § 5B1.3(a)(5) and 18 U.S.C. § 3563(a)(5). As noted above, we submit that a
condition requiring community service would be appropriate under U.S.S.G. § 5B1.3(a)(2) and
18 U.S.C. §§ 3563(a)(2) and (b)(12).
29
United States v. Van Der Zwaan, 18 CR 31 (D.D.C. 2018); United States v. Zagaytov, 17 CR
36 (D.D.C. 2017); United States v. Papadopoulos, 17 CR 182 (D.D.C. 2017); United States v.
Soto, 14 CR 108 (D.D.C. 2014); United States v. Perez, 14 CR 109 (D.D.C. 2014); United States
v. Rodriguez, 13 CR 061 (D.D.C 2013); United States v. Brooks, 12 CR 130 (D.D.C. 2012);
United States v. Polozola, 11 CR 374 (D.D.C. 2011); United States v. Rodney, 11 CR 038
(D.D.C. 2011); United States v. Walston, 10 CR 110-3 (D.D.C. 2010); United States v. Lieb, 10
CR 144 (D.D.C. 2010); United States v. Lerch, 10 CR 264 (D.D.C. 2010); United States v.
Mahler, 09 CR 266 (D.D.C. 2009). Judges in the District Court for the District of Columbia
have also sentenced defendants to probation in several 18 U.S.C. § 1001 cases where the total
offense level was 6 rather than 4, as it is in this case. See, e.g., United States v. Humphrey, 14 CR
82 (D.D.C. 2017); United States v. Silva, 16 CR 69 (D.D.C. 2016); United States v. Adams, 14
CR 161 (D.D.C. 2014).
10
resulted in a sentence of imprisonment. Both involved defendants charged by the Special
Counsel’s Office. 30 Even before taking into account his substantial assistance, as reflected in the
Government’s Motion for Downward Departure, United States v. Flynn, 17 CR 232 (D.D.C.
Nov. 20, 2018) (Doc. 47), General Flynn’s case is distinguishable from those two cases.
General Flynn’s case differs from that of Alexander Van der Zwaan, who pled guilty to
lying to the Special Counsel and failing to produce requested documents. Unlike General Flynn,
Mr. Van der Zwaan is a trained attorney who was represented by counsel during the interview;
he was interviewed at a time when there was a publicly disclosed, full-bore investigation
regarding Russian interference in the 2016 election; and he was given a warning that it is a
federal crime to lie during the interview. 31
General Flynn’s case also differs from that of George Papadopoulos, who pled guilty to
making false statements regarding his communications with Russians and Russian
intermediaries. Mr. Papadopoulos was specifically notified of the seriousness of the
investigation, and “was told that he may have important information to provide.” 32 He was
warned that lying to investigators was a “federal offense” that could get him “in trouble.” 33 Mr.
Papadopoulos’s interview was “not a hurried” encounter, and he had time to reflect on his
answers as he traveled from his home to the FBI office in Chicago to continue the interview. 34
30
See United States v. Van Der Zwaan, 18 CR 31 (D.D.C. 2018) (Docs. 1, 28); United States v.
Papadopoulos, 17 CR 182 (D.D.C. 2017) ( Docs. 1, 48).
31
United States v. Van Der Zwaan, 18 CR 31, Sentencing Hr’g Tr. 7-9, 31, 33, 37, Apr. 3, 2018.
32
United States v. Papadopoulos, 17 CR 182, Govt. Sentencing Mem. at 1, Aug. 17, 2018.
33
Id.
34
Id. at 2.
11
He met with the FBI the following month for a further set of interviews, accompanied by his
counsel, and did not correct his false statements. 35
II. The Nature and Extent of General Flynn’s Cooperation
We cannot say it any better than the Special Counsel’s Office has: Given all the
circumstances, “a sentence at the low end of the guideline range – including a sentence that does
not impose a term of incarceration – is appropriate and warranted.” 36 General Flynn provided
timely and substantial assistance to law enforcement. He agreed to a proffer with the Special
Counsel’s Office upon its first request to speak with him, and with only the scanty protections of
a typical Department of Justice proffer letter. As the Government states, his early “decision to
plead guilty and cooperate likely affected the decisions of related firsthand witnesses to be
forthcoming with the SCO and cooperate.” 37 He participated in five pre-plea proffer sessions
with the Special Counsel’s Office and fourteen additional meetings with the Government
pursuant to the Plea Agreement entered on December 1, 2017. In total, he participated in
nineteen meetings with the Special Counsel’s Office and other components of the Government,
totaling approximately sixty-two hours and forty-five minutes.
Additionally, General Flynn has produced thousands of documents to the Department of
Justice. Even before his voluntary pre-plea proffer sessions, he had chosen to produce sweeping
categories of documents held by his two companies, rather than fight over the breadth of
subpoenas, and facilitated the production of electronic devices. After his Plea Agreement, he
made another five productions of documents.
35
Id. at 6; United States v. Papadopoulos, 17 CR 182, Sentencing Hr’g Tr. 39-40.
36
Gov. Sent. Mem. at 1.
37
Addendum to Gov. Sent. Mem. at 5.
12
A false statements case with a guideline range of 0 to 6 months, on top of which the
Government has moved for a downward departure under § 5K1.1, presents a particularly strong
argument for a non-custodial sentence. Throughout the federal court system in fiscal year 2017,
a total of 130 defendants faced sentencing where the “primary offense category” was either
“Administration of Justice Offenses” (a term that includes such serious crimes as perjury and
obstruction of justice) or “Other Miscellaneous Offenses” (a residual category that includes 18
U.S.C. § 1001). According to the United States Sentencing Commission, the median sentence
imposed in those 130 cases was zero months, and the median percent decrease from the guideline
minimum was 100.0 percent. 38
III. Conclusion
General Flynn devoted his career to serving and protecting the Nation. Having made a
serious error in judgment, for which he has shown true contrition, he recognized it was consistent
with the values by which he has led his life simply to provide the facts to those charged with
enforcing our laws. On the day he entered his guilty plea, he said he was “working to set things
right.” He has done so.
For these reasons, we respectfully request that the Court impose a sentence of probation,
as described above, and community service.
38
U.S. Sentencing Commission, Sourcebook of Federal Sentencing Statistics, Table 30 (2017)
(“§5K1.1 Substantial Assistance Departure Cases: Degree of Decrease for Offenders in Each
Primary Offense Category, Fiscal Year 2017”). The table reports that “Median Sentence in
Months” was 0 and “Median Percent Decrease From Guideline Minimum” was 100.0 for 72
cases in which the primary offense category was an Administration of Justice Offense. It also
reports identical figures of 0 months and 100.0 percent decrease from guideline minimum for 58
cases in which the primary offense category was an Other Miscellaneous Offense.
13
Respectfully submitted,
/s/
Robert K. Kelner (D.C. Bar No. 466880)

Stephen P. Anthony (D.C. Bar No. 426536)
Covington & Burling LLP
One CityCenter
850 Tenth Street NW
(202) 662-6000
14
Exhibit A1
Exhibit A2
The Honorable Judge Emmet G. Sullivan November 26, 2018

U.S. District Court for the District of Columbia
333 Constitution Avenue, N.W.
Washington D.C. 20001
Re: Michael T. Flynn
Dear Judge Sullivan:
I am honored on behalf of my siblings and our families to write to you about our brother,
Michael T. Flynn. Although the circumstances of this occasion deeply sadden me, nevertheless,
writing about Michael’s extraordinary life as a child, teenager, college student, young soldier,
U.S. Army General and father, husband and friend brings joy to my heart.
My name is Clare Eckert. Michael is my younger brother by nearly a decade.
The age difference between Michael and I is significant as I helped care for him as an infant,
watched over him as a toddler and stood in awe as he grew up to be a remarkable man of deep
conviction, impeccable character and high moral principles. Throughout a lifetime of
achievements that I have personally witnessed, Michael’s behavior has demonstrated the
virtues of courage, bravery, integrity, humility, compassion for others and an unwavering faith
in God and love for his country and his family.
Michael was born on to Charles F. and Helen F. Andrews Flynn

(deceased), two Irish Catholics who raised nine children. Our father served for 20 years in the
United States Army, including in both World War II and the Korean War. He retired as a
Sergeant First Class. Our mother was an intellectual. She was valedictorian of her high school
class and went on to eventually earn her Juris Doctor degree at 63 years old from New England
School of Law. Our family was a military family. We lived in Army quarters in the United States
and overseas.
1|Page
Our parents were salt-of-the-earth people who inspired us to be independent thinkers, good
and honest hard-working people, life-long learners, team players and respectful of others.
My brothers, sisters and I were intentionally named. Many of us were named after Catholic
Saints. Michael was named after Saint Michael the Archangel. As fate would have it and as my
mother and I would often talk about, Michael’s life experiences and 33-year military career
would come to emulate his namesake as a “protector and the leader of the army of God against
the forces of evil.” There are many examples in his life that establish the uncanny resemblance
he has to his namesake, particularly with respect to Michael’s distinguished moral fortitude and
inner strength of character.
When Michael was 13 years old, his quick thinking and determination prevented what was sure
to be an accidental death of two toddlers as they played in the path of a free-rolling car. A third
child had climbed into the car and released its emergency brake. As the car rolled down the
driveway towards the toddlers, Michael, who was nearby with a friend, took immediate action
and control of the situation by plunging to grab one child out of harm’s way while at the same
time directing his friend to do the same for the other child. Those children’s lives were literally
saved that day. When the community discovered his feat of heroism, the local newspaper
recognized Michael for his unselfish act.
The instinct to serve as a caretaker, trusted guardian and a voice of reason has always come
naturally to Michael. I don’t remember Michael ever complaining or putting up a fuss when
asked to help around the house. Considering our small home and large family of 11 with
children of all ages, conflict and tears were unavoidable. Michael, however, as a middle child
and positive attitude and balanced temperament, learned to be an arbiter of conflict and
calming force early on. I could always depend on him to help me take care of the “little kids” as
we called the youngest three when I was put “in charge.”
Today, I fondly remember, during my teenage years, the many times that I’d be on my way out
of our home and Michael would poke his head from the front door of the house wanting to
know when I would be returning. Looking back, it was as if he was the last check-in to tell me to
2|Page
take care of myself because he would be awaiting my safe return. He was no more than seven
years old when he began this routine with me. As I sit here today and take inventory of his life,
this behavior of watching over others and solving problems has proved to be permanent
character traits of Michael.
Michael is also a natural born leader, willing to face obstacles head-on, build teams, and power
through challenges with sheer strength of moral character and deep conviction in his belief in
fairness and treating others the way he would want to be treated. In so many instances, I have
witnessed him inspire myself and countless others during heartfelt remarks to soldiers and their
family members during many Change of Command ceremonies. One such ceremony will always
hold a special place in my heart. It took place at Fort Bragg in North Carolina. Michael’s wife
and love of his life for nearly 40 years, Lori Andrade Flynn, and their two young sons, along with
many members from both of their families were in attendance.
This particular ceremony is special to me because, at the time, our Dad was nearly unable to
attend. He was in significantly bad health having lost his toes on both feet to diabetes. In fact,
doctors insisted that our Dad refrain from flying from Rhode Island to North Carolina for
medical reasons. Our father was intent on being there for Michael and so my husband and I
happily drove my parents to Fort Bragg. During Michael’s speech that day, he extended
tremendous gratitude to our father as a veteran enlisted man of World War II and Korea.
Michael selflessly took this opportunity to not only publicly acknowledge his father’s service,
but to give thanks and praise to all soldiers, regardless of rank, for their contributions and
service to America and the world. Michael’s humility, compassion for others and sense of
profound love for soldiers, his family and his country are unmatched. My father talked about
Michael and his speech for hours on our ride back to Rhode Island. He was so touched and
proud that Michael acknowledged him and the enlisted men and women. My Dad explained
that during his 20 years in the Army (until 1963 when he retired as an E-7) he had never heard
an Army officer give such heartfelt thanks and praise to the rank-and-file soldiers for their
sacrifices.
3|Page
Michael has shown the same humility and love for his family time and time again. Whether he
gladly visited the local Senior Citizen Center as the “invited guest speaker” or made a
congratulatory call or sent a note or email to a brother or sister or niece or nephew about an
accomplishment that he had heard about through the family grapevine, he ALWAYS found the
time for others. On holidays, we, his brothers and sisters, could always count on Michael to be
the first one of us to start an email thread to reconnect wherever we were in the world and let
us know he was thinking of us and hoped we enjoyed whatever holiday it was.
Over the years, he has made it a priority to reach out to soldiers’ families when they deployed
and has mentored many young soldiers along their journeys, including his own nieces and
nephew who have joined a military branch of service. He is a trusted friend and confidant who
has maintained life-long friendships even as he traveled the world.
When he retired from the Army, I was there, as were many of his family members and friends,
to hear him graciously give thanks to the hundreds and hundreds of military men and woman
and civilian employees from all branches of military and government who attended the
ceremony and/or helped him along the way. Michael’s innate kindness, unselfish nature and
sincerity all come from deep inside his heart and they remain steadfast to this day, evident
through his daily interactions with his family, his friends and all those who cross his path. Earlier
this year, one of our sisters, Mary, completed her master’s degree. When Michael arrived at a
small gathering to celebrate this achievement, he came with a large helium “Congratulations”
balloon and a card in hand for Mary. This is the kind of brother Michael is – he always shows up
and is always thoughtful and always kind.
When Michael was in high school, he was president of his class, captain of the football team
and an all-around great athlete and student. He was well-liked and respected by his friends and
teachers. At one of his football games that I attended with our father, I will never forget a
certain kick-off play that sent chills down our spines. As the whistle blew in a quiet stadium to
start the game, Michael led the defensive field of players with his arm raised, finger pointing to
4|Page
the sky proclaiming for his teammates to “CHARGE!”. Down the field, these young teens
followed Michael. As my father and I watched him lead the way, we looked at each other in
awe knowing that we had just experienced the dynamic strength of Michael’s leadership in
action. My Dad and I would often remember having witnessed this extraordinary and
sentimental moment as Michael’s military career took off. It exemplified what he would
become later in his life as a three-star Army General – a trustworthy protector and leader of
men and women in the most critical war time situations against evil forces that one can only
imagine.
Later, while he was in college at the University of Rhode Island on a ROTC scholarship and
playing water polo, I would attend the games. Water polo is a sport of mental and physical
toughness and endurance. I would watch Michael excel at motivating and directing his
teammates to fight on, even as the constant turbulence of the water and rough and tumble
action of play allowed for little oxygen and low visibility as to the whereabouts of the ball.
Taking it easy or giving up to Michael were never options. His intensity to work hard at
everything he has done over his lifetime has never ever wavered.
This competitive swimming experience, along with his years as a lifeguard and his year-round
love for surfing along the coastline in Rhode Island, would serve him well in the Army on a
deployment to Grenada early in his career. It was in Grenada that he risked his life to save two
soldiers who had taken a raft off a local beach and found themselves in a desperate situation:
They were holding on to a deflating raft while drifting out to sea in strong currents. Michael had
been alerted to this life-threatening situation, saw the two men slipping from their deflating
raft into the rough seas and, without hesitation, jeopardized his own life and well-being in an
effort to save them. Instinctively, he knew they needed help and that time was of the essence.
His fearless determination and compassion for others kicked into action as he sprang from a 40-
foot cliff into the swirling water below and rescued the two soldiers, safely swimming each
soldier onto a ledge of the cliff, where later they would be airlifted by helicopter to land for
medical care.
5|Page
Risking it all for the sake of others is not uncommon for Michael. Every day of his military career
countless soldiers, civilians and their families in America and on foreign soil depended on
Michael’s decision-making skills and reflective insight for survival and to help them through the
most difficult times. When our family learned that he was receiving backlash for a report he
authored to “fix” our country’s military intelligence systems, we had his back and understood
that Michael knew it had to be done in order to save lives and protect freedom. The visionary
intellectual capacity Michael has exhibited throughout his life may not be appreciated by those
unwilling to stand up and take necessary stances in the name of freedom and truth, but
Michael’s tenacious ability to manage difficult tasks and to stand alone, when necessary, to do
the right thing is undoubtedly his legacy.
Michael will also be remembered for the hundreds of thousands of relationships he built over
his life. He is a warm-hearted person who understands that to know a person, one must listen
and learn what matters to them. Prior to Michael’s appointment as Director of the Department
of Army Intelligence, he traveled the United States meeting with state law enforcement
departments and their staff. He has deep respect for public servants and these sessions, among
other reasons, were to discover how police officers and their communities operated and where
intersections with his expertise in the military could be utilized to help keep Americans safe in
their homes. Michael and I talked about this experience and his unbridled recognition as to the
critical importance of local communities and their public servants for maintaining the welfare of
the public.
This is but one example of our philosophical discussions about the world around us whenever I
visited him at his home or when he was visiting Rhode Island. If he was in Rhode Island, these
conversations would often include our mother who was an avid reader. It would be very typical
for the three of us to sit on the porch of our family home and debate the latest headline news
event whether the topic was the local town budget or a new technological advancement that
could change the world. The conversations would flow from one topic to the next. Despite all
the superficial and downright false news reports about him, Michael is a deep-thinker,
6|Page
contemplative and a serious scholar with vast interests well beyond his expertise in military
intelligence. The reality is that Michael is a respectful professional and genuine, loving person.
Michael is not a politician. When he left the Army in August 2014, he and his wife Lori came
back to Rhode Island. At the time, campaign politics was not on his mind. He and I talked about
his next career move as potentially becoming a business owner. Having owned my present
business for 14 years, he and I would converse about the various challenges and opportunities
of business ownership. The chance to strike out on his own and work with his oldest son was
something we discussed at length. It wasn’t until 2015 that he started his own business, thus
his time spent as a business-owner before political personalities called upon him for his foreign
policy expertise was a very short time.
Our family was relieved for Michael, Lori and their sons and two grandchildren when he did
retire. (Michael would add a third grandchild in April 2017.) We knew Michael would not be
going back to a war zone and we would all get a chance to see him, Lori and the kids more
regularly. He is a wonderful father and grandfather and loves spending time with family. He
always speaks with a gleam in his eye and love in his heart about his three grandchildren. They
call him “PaPa” and his grandkids love his warmth and caring nature, just as we all do. He is one
of those grandfathers that will gladly sit at the ocean’s edge and help build sandcastles or
volunteer to take the kids for long walks along the shoreline so he can spend even more time
with them. Michael has always had more enthusiasm for life and energy than anyone else I
have ever known. I remember him running barefoot from his wife’s family home to our family
home in the early morning hours to have a coffee with our mother. The distance of that run is
about five miles along side roads and rolling hills. Michael has amazing stamina and strength!
When Michael was called upon to serve his country again as an advisor to political campaigns, I
knew he would give his all and do his very best. Little did I, or anyone in our family, realize what
the future would hold for Michael and all of us who have all been profoundly affected by the
devastating events that have transpired over the last few years. Michael is loved by his siblings
7|Page
and our families. He has been and continues to be the rock for all of us. He has stood by all of us
through our own trials and life challenges and brought immense pride to us all. When our
mother died at 89 years old in December 2014, Michael’s U.S. Army Airborne wings were laid to
rest with her. For two years prior to her passing, I spent as much time as I could with her and
would always visit her at least one weekend day. If it was Sunday, the phone was always nearby
wherever she and I were sitting because Mom was waiting for her Sunday call from Michael. He
never once missed making that call to our Mom. I was there, and I know how much his phone
calls meant to her.
Michael’s life is remarkable. In my opinion, he is one of the few transformative change agents
that history will define for his contribution to the search for world peace and for his willingness
to stand up for his beliefs and for others’ rights. He told the truth when it mattered the most to
the public and to this country. He has written a best-selling book on his vision to fight global
terrorism, and very significantly to me as a woman in the workforce, when he was alerted to
the mistreatment and discrimination against a female FBI agent by her superiors, he took action
as a high-ranking military officer and publicly supported her without concern for himself, the
powerful enemies he may make or his own career. That is who he is.
He has saved countless lives as part of his life experiences beginning as a 13-year-old boy,
continuing as a young soldier who rescued two soldiers caught in the ocean’s current, and as an
intelligence officer willing to accept the risks to tell the truth in an effort to ensure the safety
and security of civilians, American soldiers and our allies and countrymen in America and
abroad in warring and war-torn nations.
Perfection escapes humans. We are all imperfect, including my loving brother Michael, who has
paid dearly since finding himself in a predicament where he now faces a Court of law, to be
sentenced based upon his plea agreement to an Information charge of making a false
statement.
8|Page
It is my hope and belief, Your Honor, that justice will be served and Michael will walk out of
your courtroom a free man to the loving and open arms of his family. Thank you, Your Honor,
for considering my words of support for my brother Michael as you determine his sentence. I
am available, at any time, to offer additional insights about my beloved brother Michael.
Sincerely,
Clare (Flynn) Eckert
Saunderstown, Rhode Island 02874
9|Page
Exhibit A3
29 November, 2018
The Honorable Judge Emmet G. Sullivan

Dear Judge Sullivan,
I am Jack Keane, former Vice chief of staff, US Army, retired in October 2003. I
was in the Pentagon on 9/11, lost 85 teammates, and oversaw the wars in
Afghanistan and Iraq. After retiring, much to my surprise, I was asked to assist the
generals who were fighting both wars, all of whom I had worked with at some
time during their careers. My involvement lasted well over a decade to include
almost four years assisting Dave Petraeus in both Iraq and Afghanistan.
It was during my tenure as Vice Chief and my repeated visits to Iraq and
Afghanistan that Mike Flynn came to my attention, first, as a rising star,
intelligence officer, and after, as the officer who single handily changed how we
created, processed and used intelligence during combat in the 9/11 wars.
For your understanding, Iraq and Afghanistan are unconventional wars where
the enemy, while using relatively low technology weapons, was a master at
deception, by hiding in and the among the people, often in full view. The US
intelligence system which served us so well during the Cold War, Desert Storm,
the invasion of Afghanistan and Iraq, was designed to find and assess an enemy
who moved in ground and maritime formations, had tank parks, airfields and
shipyards, which could be seen by our national overhead systems or listened to by
our national signal intelligence systems. This conventional intelligence gathering
was of little value to those fighting the 9/11 Wars.
Mike Flynn grasped that reality as a change agent and innovator and by sheer
force of persuasion, uncommon good judgment and moral courage, he changed
the US operational and tactical intelligence system, making it responsive to our
warfighters. At their fingertips was valuable information from data mining,
photographs of suspected terrorists, behavior patterns of enemy leaders and
their organizations, transcripts of phone conversations and terrorist email
exchanges. There is no doubt that Mike's contribution was consequential to
mission success and the preservation of life.
The pattern of innovation and change continued as the top intelligence officer
at Central Command who oversaw the Middle East and South Asia theater and
the Department of Defense's top intelligence officer as the Director of the
Defense Intelligence Agency.
On a personal level I know Mike to be a family man, a devout Catholic and a

person of character and integrity. I trust Mike completely and always will.
Sincerely,
Jack Keane
General
US Army, Retired
Exhibit A4

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Exhibit A5
Exhibit A6
John Jeffery Bucklew

Garden Florida
13 November 2018

Honorable Judge Sullivan,

Understanding all that Mike is going through, I am sending this to you on his behalf. If you will please
allow (I know nothing about how these types of letters are written), I will leave you with some stories of
our relationship and his character as I have known him since 2004.
I have had the pleasure of serving and knowing him since he was a Colonel, our Director of Intelligence
with the Joint Special Operations Command of the United States Special Forces Command. We met in April
of 2004, when my helicopter (Chinook 47) made a hard landing at Baghdad International Airport. Flying
back from Fallujah, we were shot up by unidentified weapons and landed fairly quickly – and hard – in the
middle of the night. The crew chief screamed to all of us “Un-ass the ship RIGHT NOW MOVE MOVE
MOVE”. I was still young then, just 44 years old, however I’d been disabled since 1998. Running off the
Helo with my backpack, equipment and hauling a tuff bin (big box full of stuff I should have just left), I run
into some random guy in the way. I move left, he moves left, I move right, he moves right, it might have
been funny had the chopper not been at risk of catching fire. Finally this random man grabs one end of my
tuff bin and helps me carry this box while saying “Hi, I’m Mike Flynn, I’m your new boss”. My response?
“That’s nice, Colonel – RUN FASTER”. This is how I meet the man with whom we created serious impacts
against the Jihadist threats at the time. Any other man might have stood aside, being an officer and a high
ranking one, at that, yet Mike stepped in and helped. That’s the Irishman that he is.
While I cannot go into detail, I can say that Mike displayed leadership through actions – not mere words.
He was NOT your average officer which most of those who serve or had served had come to expect. Mike
is a do-er, a man of action. While he is good at defining and giving guidance, one thing that set him aside
was this. Most officers like to be “briefed” on any given subject, and then make decisions based upon time-
restrained briefings. Mike was not that way. He asked (did not command, he ASKED) if he could please
kindly be CC’d on all our emails. Not specific briefing emails, but ALL our discussions. We, as intelligence
professionals, would have endless discussions through emails about any given subject. Being on the CC
lines of these emails allowed him to see ALL the discussions which would amalgamate and condense into
the briefings he needed to give to our Commander, MG/LTG McChrystal at the time. Mike read these
emails in order to gain a more complete understanding of not only the subjects involved, but moreover to
gain insight into all the professionals under his leadership, how we thought, the aspects from which we
would view subjects, the varied levels of experience each discussion would uncover. Mike is not a “one
bang for the buck” kind of man. He regularly acted as he did so that every action he conducted would give
him three or four returns for every effort expended. He was smart that way, understood the value of the
returns of his actions, gaining more insight and better clarity each and every day. Being a 32 year
professional I can say the people using that approach were rare, indeed. Mike Flynn defined that rarity.
So as not to make this too long to care to read (I’m old, I know I ramble), I will say that America right now
would not be as safe as it is, today, had it not been for Mike Flynn enabling all his professionals to do our
jobs. He believed, constantly questioned, enabled, and received our full support after making any decision.
I will stand up for him until the day I’m buried, and even then I’ll do it from Heaven. I have no higher
praise than that.
Sincerely,
John Bucklew
P.S. Should you seek me out, Judge, know I am currently
Page 2
Exhibit A7
Exhibit A8
Exhibit A9
Exhibit A10
Exhibit A11
Exhibit A12
Exhibit A13
Exhibit A14
Exhibit A15
Exhibit A16
Exhibit A17
Exhibit A18

333 Constitution Ave, N.W.
My name is Margaret McDeed from Dover, Florida. I offered to write a letter of support for General Michael
Flynn (Mike) because quite frankly, I am honored to have the opportunity to do so for such a great, warm,
loving man. I have known him and his family personally for over 15 years. We initially met when my husband
(who is now retired from the Army) returned from deployment from Afghanistan and were stationed at Fort
Huachuca, Arizona. Also, my husband worked for and along with Mike at MacDill Air Force Base in Tampa,
Florida several years later when he returned from deployment from Iraq. At both locations we had spent time
together at many military family events and functions and Mike was the type of person that would always ask
how you were doing and if there was anything needed. He always cared about the families on post and the
base and his love for our country is so evident. Everyone that I know who has either worked with him in the
military and/or knows him in the civilian sector all say the same thing - What a patriot and brilliant officer he
is, and they couldn’t know a nicer person. This is so true and all words of his character!
When I initially met the Flynn’s there was a genuine warmth and friendliness they exuberated and I felt so
comfortable around them. Through the over 20 years of being a military spouse I have been fortunate to meet
many people and make friends all over the world. But when it came to the Flynn’s I knew it was going to be a
lifelong friendship and all these years later I was right! The Flynn’s would take several trips to Tampa when
their son Matt lived near me and I always had them over for a special Italian meal while they were visiting.
Their two grandchildren were here and they always flew in for birthdays and special occasions. Their world
revolves around their grandchildren and devotion to family so apparent. On one of those trips to Florida, my
mother asked if she could come to meet Mike. I asked him if it was okay to have them come over as well and
he said absolutely, and he was more excited to meet them! I explained how my mother is a caregiver for my
sister who suffered brain damage when she was born, and my father suffered a stroke when he was only 52
years old. He was paralyzed on the right side of his body and lost the ability to speak; however, is able to walk
with a cane. Anyway, when my parents walked in he got right up to hug them as if he knew them all their lives.
When we sat down, he positioned himself next to my father and held his hand. It warmed my heart because I
knew how excited my 80 year old father was to meet him and he could not communicate with us but with Mike
holding his hand that was like speaking a thousand words. When I spoke to my mother the next day she said
how honored she was to meet him and what a beautiful person he is inside and out and really enjoyed the
visit. They both could not stop smiling and they too have grown to love him and have so much respect for him.
This is just one example and one story of the type of person Mike is. He cares about people and it is so apparent
when you see him interacting with his family, especially the grandchildren, and friends.
I feel truly blessed to know Mike, Lori and their family and I am grateful that all those years ago my husband
received orders that gave us the opportunity to cross paths. Thank you so much for your time.
Sincerely,
Margaret McDeed
Dover, FL 33527
Exhibit A19
Exhibit A20
Exhibit A21
Exhibit A22
Exhibit A23
McJunkin Family
Charitable Foundation, Inc.
Plantation, Fl. 33317

333 Constitution Avenue, N. W.
Washington, D.C. 20001
The McJunkin Family Charitable Foundation is pleased to provide this letter of character support for General Flynn.
General Flynn continues a relationship with our foundation since March 2016. Our Board members (Patricia
Houchens, Ken Jones and Marian Elmore) all agree the General is a respected and valued liaison for the Veterans
and our organization.
We are a small private family foundation that was founded by a proud World War II Army Air Corps Veteran and his
wife (W.S. and Frances McJunkin). We are charged with funding three major areas: Medical, Salvation Army, and
Veterans.
Our goal is to research and obtain reputable information on organizations that we will have the opportunity to fund, with
this in mind we reached out to General Flynn.
Out of his deep commitment to our American Veterans, General Flynn has provided us with valuable information and
personal introductions to organizations that assist our Veterans, they include: Special Operation Warriors Foundation,
Inc., Operation 300, Gold Star Families, and Angel Brigade Radio. The information provided us the opportunity to do
our due diligence on these organizations and evaluate how they fit with our foundation. We enthusiastically fund
Special Operation Warriors Foundation and Operation 300.
The McJunkin Family Charitable Foundation is honored to have the privilege of having General Flynn as an unpaid
consultant.
Sincerely,
Patricia Houchens, President, MFCF, Inc.

Ken Jones, Vice President, Secretary, MFCF, Inc.
p.p. Marian Elmore
Vice President, Secretary, MFCF, Inc.
Exhibit A24
Exhibit A25
Date 129

U.S. District Court for the District of Columbia 333 Constitution Avenue, N.W.
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Exhibit A26
Date129


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Sincerely,
:LOOLDP7%HFNPDQ
6XPWHU6&
Exhibit A27
Exhibit A28
Exhibit A29
Exhibit A30
Exhibit A31
November 21, 2018

United States District Court for the
District of Columbia
333 Constitution Avenue, NW
RE: General Michael T. Flynn
My experiences with General Flynn have all been impressive since I knew him
when he dated my cousin Lori Andrade and eventually married her. He has been a
kind, family oriented, a true leader, and a good example of a god fearing
individual. He makes my family and I feel good about ourselves and always a true
patriot that we all trusted. He attended our church when in town and was available
to give helpful advice and choices to his younger extended family members. I
appreciate this opportunity to describe my personal familiarities with this
wonderful individual.
For over forty years, I witnessed him at our many family functions and always
found him to be a gentleman, respective and attentive to the elders, children and
everyone around him.
While following his military career, I was privileged to go to one of his

Chain of Command Ceremonies and witness first-hand how General Flynn
interacted with everyone no matter what station in life they were. I can remember
on many occasions of him walking into the dining room and immediately going
behind the serving line to greet and thank everyone by name for being there that
day. The reaction of his friends, fellow soldiers, and coworkers was moving.
Whenever I was with Mike, he was always the first to stop and greet everyone. At
a family function or gathering Mike would be the first one to come over and
introduce you to the crowd to make you feel welcome.
One of his most accommodating gestures I remember was when my nephew

was interested in military service. Mike took time to sit and speak with him about
the pros and cons of joining the armed forces. Over the years when Mike was
home on leave, he always made time for my mother and other relatives in his
extended family either by birth or marriage. A faithful son, he spent many a day
with his parents. His mom loved to walk the beach and when Mike was in town he
would make it a point to leave early each morning to meet his mom for their
morning walks at the beach despite his busy schedule and responsibilities.
I hope my personal picture of General Flynn is effective to describe him as a

true Patriot, a loving family man, loyal to his friends and faithful to God.
Sincerely,
Cheryl Quinn
Cheryl Quinn
Tiverton, Rhode Island 02878

Exhibit A32
The Honorable Judge Emmet G. Sullivan 1 December 2018


I had the honor to serve with Lieutenant General Michael Flynn during my Army career and
continue to call him a friend. From 2002-2004, LTG Flynn was my direct supervisor when I
served as a Battalion Commander for the 344th Military Intelligence Battalion, Goodfellow Air
Force Base, Texas. My situation was unique in that I was the first single parent to be selected and
serve as a Battalion Commander in the Army. There was significant doubt voiced by senior
officers that I could effectively command due to my single parent status. One month after I
started, Colonel Flynn took command of 111th Military Intelligence Brigade at Fort Huachuca,
Arizona.
From our very first meeting and throughout my two years in command, he consistently
demonstrated and demanded I maintain the highest values of an Army officer to include respect,
honor, integrity, selfless service, and loyalty. His unwavering confidence in my abilities
empowered me to make complex and difficult decisions. I was the one commander out of the four
who served several states away from the Brigade headquarters. In addition to his regular phone
calls to check in to discuss how my command was going, I knew I could always call and get
through to him days, nights, and weekends if we needed support or to ask for advice. Despite
heavy wartime training demands, he flew out to Texas at every opportunity and spent time
teaching and listening to the officers and soldiers. He genuinely cared for and enjoyed spending
time with each soldier. He shared his keen leadership insights, asked questions to learn more
about our issues and successes, challenged us to uphold our commitment to integrity and honor,
and built team morale by attending unit social functions and joining our physical training
sessions. He was a genuine leader who valued people and proudly upheld Army values.
I trusted him to guide and provide me opportunities to succeed and grow as an Army officer. At
that time in the Army, many senior officers were dismissive or unsupportive of the woman
officers coming up through the ranks for the first time. In contrast, Mike Flynn sincerely invested
in my professional success by mentoring and supporting me as I navigated that very challenging
career path. When I moved on to subsequent military positions, promotions, and life after the
Army I kept in contact with Mike Flynn because I genuinely trust his advice, candor, integrity,
and commitment to our Nation and the values we hold so dear.
Michael Flynn is a man of honor and commitment. I have and still do trust him with my life.
Sincerely,
Sharon R. Hamilton
Colonel (Retired), U.S. Army
Dahlonega, GA 30533
Exhibit A33
Exhibit A34
Exhibit A35
Exhibit A36
Exhibit A37
Exhibit A38
Exhibit A39
Exhibit A40
Exhibit A41
Exhibit A42
Exhibit A43
Exhibit A44
Exhibit A45
Exhibit A46
The Honorable Judge Emmet G. Sullivan 01 December 2018

Multiple letters will be written and at the end of all those letter it will show a similar finding. Mike
Flynn loves his Family, Country and puts forth others before his own personal needs without
question.
I have had the opportunity to witness this type of selfless character multiple times over the years.
Mike puts his family first. I once drove his wife Lorie to Andrews Airforce Base to see Mike coming
back from Afghanistan. Watching Mike getting off the plane and seeing Lorie about to jump out of
her seat waiting for Mike to exit the aircraft, they were like to newlyweds. Another time I had Mikes
Son with me in Afghanistan as an analysis and I needed to send him out with ground forces to
conduct intelligence collections. I knew who this young man was and his father. I sent him out
called Mike in Kabul, at the time I was in Kandahar and told him his son was out on a mission but
wanted to give him a heads up. Without hesitation he simple said thank you for taking care of my
Son. He put the mission first and expected that from others.
Words will never truly measure ones character or commitment, but trends, themes and
observations do tell a story. Mike is a man of good character, loves this Country and puts his
family first.
Sincerely,
Tres Hurst
Harry H. Hurst III (Tres)
Executive Vice President – Cotton Commercial USA, Inc.
MAJ (Retired) United States Army
SES ((DISL) Retired)) United States Army
Houston, Texas 77009

Exhibit A47
Exhibit A48
Exhibit A49
Exhibit A50
The Honorable Judge Emmet G. Sullivan 30 November 2018
I am writing to you today on behalf of and in support of a great American, husband, father,
friend, mentor and leader, Lieutenant General (Retired) Michael T. Flynn. I have had the honor and
good fortune to know LTG (Ret) Flynn since 1996. We have served together in peacetime and wartime
and have developed a long-time friendship based on respect, admiration and trust. I have trusted my
life to Mike Flynn and would do so willing again today. He is quite simply the finest solder and leader
with whom I’ve had the honor to serve and is unquestionably one of the finest men I know.
I humbly ask that as you consider his sentence that you please keep ŝŶ mind his lifelong
commitment to his country, the countless thousands of lives that he has positively influenced and his
future capacity to do great things for our beloved country and its citizens.
If I can be of any assistance in this matter, please do not hesitate to contact me. Thank you for
your consideration.
Sincerely,
Timothy P. Kiely
Colonel, United States Army (Retired)
Colorado Springs, Colorado 80919

Exhibit B1
Exhibit B2
Exhibit B3
Exhibit B4
Exhibit B5
Exhibit B6
Exhibit B7

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Case 1:17-cr-00232-EGS Document 50 Filed 12/11/18 Page 1 of 178

UNITED STATES DISTRICT COURT

UNITED STATES OF AMERICA

DEFENDANT’S MEMORANDUM IN AID OF SENTENCING

Counsel for the Defendant

December 11, 2018

I. A Sentence of Probation Is Warranted In Light of the 18 U.S.C. § 3553(a)

A. The History and Characteristics of the Defendant ............................................ 2

B. The Nature and Circumstances of the Offense .................................................. 7

II. The Nature and Extent of General Flynn’s Cooperation ............................................ 12

III. Conclusion ....................................................................................................................... 13

A1. Frank Larkin, former U.S. Senate Sergeant-At-Arms

A2. Clare Eckert, on behalf of Flynn siblings

A4. Colonel Yvette Hopkins (Ret.), U.S. Army

A5. Captain Seth Walters, U.S. Navy

A6. John Bucklew, United States Southern Command

A7. Kris Hager, Gold Star father

A9. Joe Flynn, brother

A12. Katherine Velez, Civilian Officer, Department of Defense

A13. Colonel Thomas Heaney (Ret.), U.S. Army

A14. Admiral Paul Becker (Ret.), Rear Admiral, U.S. Navy

A15. Rosalinda Ortega Pemberton, former Executive Assistant

A16. Nancy Walters, Army spouse and family friend

A17. Colonel Christopher Vanek, U.S. Army

A18. Margaret McDeed, Army spouse and family friend

A19. Lt. Colonel Scott McDeed (Ret.), U.S. Army

A20. Colonel Tom Faust (Ret.), U.S. Army

A21. Patricia O’Connell, Army spouse and family friend

A22. Marian Elmore, Vice President of McJunkin Family Charitable Foundation

A24. Major General Robert Walters, U.S. Army

A25. Paula Beckman, Army spouse and family friend

A26. Master Sergeant William Beckman (Ret.), U.S. Army

A27. Kimberly Becker, Navy spouse and family friend

A28. George Andrade, brother-in-law

A29. Elizabeth MacPherson, Army spouse and family friend

A30. Colonel Joseph Blair (Ret.), U.S. Army

A31. Cheryl Quinn, cousin-in-law

A32. Colonel Sharon Hamilton (Ret.), U.S. Army

A33. Captain Agustin Taveras (Ret.), U.S. Army

A34. Colonel Rey Velez (Ret.), U.S. Army

A35. Colonel Nichoel Brooks, U.S. Army

A36. Colonel Benjamin Clark (Ret.), U.S. Army

A37. John MacPherson, family friend

A38. Barbara Ledeen, family friend

A39. Sergeant Steven Kallemeyn (Ret.), U.S. Marine Corps

A42. Colonel Andres Nazario, U.S. Air Force

A44. Colonel Joseph Cox (Ret.), U.S. Army

A45. Colonel James Waurishuk (Ret.), U.S. Air Force

A46. Major Harry Hurst (Ret.), U.S. Army

A47. Lyndon Searles, Civilian Officer, Department of Defense

A48. Colonel Anthony MacDonald (Ret.), U.S. Army

A49. Lt. Colonel Michael Herbert (Ret.), U.S. Army

A50. Colonel Timothy Kiely (Ret.), U.S. Army

Military Service Materials

B1. Form DD-214

B2. 2004 Legion of Merit Citation

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