Why? Its in the motion to dismiss. Theres no need to explain when the motion is quite clear what the reasons were to dismiss. Barr did not come to this decision in a vacuum. It was based on investigations done by independent US Attorneys from outside the beltway who had access to inside information from the FBI and DOJ investigations and documents on the Flynn case. THEY FOUND the exculpatory evidence that had been hidden from the court and the defense.
Over two years ago, Sullivan ordered the Mueller prosecution to hand over any evidence in the case to Flynn’s lawyers. We now know that those same prosecutors hid that evidence from the court and Flynn’s lawyers, and never turned it over. As you said, the request for dismissal would provide all that evidence of prosecutorial malfeasance to the Judge to back up the dismissal request. So why is Judge Sullivan deliberately ignoring the evidence that’s been handed over to him? Why is he ignoring the proof of prosecutorial malfeasance?