Case 1:17-cr-00232-EGS Document 102 Filed 08/14/19 Page 1 of 4 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, Plaintiff, v. Criminal Action No. 17-232-EGS MICHAEL T. FLYNN, Defendant. MOTION FOR ORDER CLARIFYING TRAVEL PARAMETERS Michael T. Flynn (Mr. Flynn) by and through his counsel Sidney Powell, respectfully requests this court issue an order consistent with the Court’s comments at the hearing on June 24, 2019, and clarify his ability to travel throughout the United States in compliance, coordination, and with the permission of his Pre-Trial Services Officer. 1. Mr. Flynn’s lead counsel resides and has offices in North Carolina and Texas. Two of his siblings, with whom he is very close, reside in California. Events are scheduled in Tennessee and Georgia in the next couple of months, one is to fundraise for veterans and the other event is to fundraise for his Legal Defense Fund. 2. As the Court stated at our hearing on June 24, Mr. Flynn is not to be treated any differently than other defendants, and we do not request special treatment. Rather, we simply request that he be allowed to coordinate his travel with his Pre-Trial Services Officer with whom he communicates regularly—as the Court suggested at the hearing1—and that he 1 The Court said on June 24: “but there are no impediments to him traveling as long as he -- and I don't want to misspeak, but pretrial has procedures in place. You have to let them know a certain number of days or hours beforehand. There are -- they aren't going to -- they're not going to impede Case 1:17-cr-00232-EGS Document 102 Filed 08/14/19 Page 2 of 4 be allowed to travel within the continental United States as needed after obtaining permission from his Pre-Trial Services Officer and complying with whatever requirements are routinely imposed. 3. It is beyond dispute that Mr. Flynn poses no risk of flight. He has effectively been on probation for close to two years; he has traveled to Korea and back, and he has surrendered his passport. 4. Mr. Flynn served his country with the greatest distinction for thirty-three years, including five years in actual combat on missions. Mr. Flynn wrote a blank check on his very life in service of this country—as have numerous other members of his family currently and in the past. 5. Mr. Flynn is a protector of others and defender of liberty. He has borne enormous responsibility throughout his life, and he will voluntarily report to prison if that is required. 6. The government voiced no opposition to this motion. Mr. Van Grack advised that government counsel defer to the Court and pretrial services on any restrictions. 7. For these reasons, Mr. Flynn requests that this Court enter an order consistent with its comments at the hearing on June 24, 2019, that Mr. Flynn’s travel would not be impeded and that Mr. Flynn be allowed to coordinate his travel throughout the continental United States as required by and with the permission of his Pre-Trial Services Officer as others do. on his ability to travel, . . . I'm certainly not impeding his ability to travel, but he just needs to follow the procedures like everyone else.” Hr’g Tr. 7, June 24, 2019 (p.m). Case 1:17-cr-00232-EGS Document 102 Filed 08/14/19 Page 3 of 4 Respectfully submitted, s/ Jesse R. Binnall Jesse R. Binnall, VSB # 79292 Harvey & Binnall, PLLC 717 King Street, Suite 300 Alexandria, VA 22314 Tel: (703) 888-1943 Fax: (703) 888-1930 jbinnall@harveybinnall.com /s/ Sidney Powell Sidney Powell, P.C. 2911 Turtle Creek Blvd., Suite 300 Dallas, Texas 75219 Tel: 214-707-1775 sidney@federalappeals.com Admitted Pro Hac Vice Case 1:17-cr-00232-EGS Document 102 Filed 08/14/19 Page 4 of 4 CERTIFICATE OF CONFERENCE Undersigned counsel conferred by email today with Mr. Van Grack and Ms. Curtis who advised that the government defers to the Court and the Pretrial Services Officers on the terms of travel requirements. /s/Sidney Powell Sidney Powell, P.C. 2911 Turtle Creek Blvd., Suite 300 Dallas, Texas 75219 Tel: 214-707-1775 sidney@federalappeals.com Admitted Pro Hac Vice