In his reply, John Gleeson argues that DOJ didn't respond to the points he made in his brief, but DID invent a new reason to explain the motion to dismiss. It's true, DOJ has abandoned much of the Tim Shea brief.
Gleeson: DOJ didn't even try to defend their materiality argument.
Gleeson invokes SSCI agreeing with his point on materiality.
Gleeson, citing DOJ disagreeing with DOJ on materiality (finally).
Gleeson describing DOJ abandoning its past claims abt materiality.

"The Government seeks to conceal its retreat by kicking up administrative dust, but the bottom line is that it no longer stands by its own motion’s implausible reasoning."
Oooph.

Gleeson points out that DOJ's NEW reason why they have to dismiss is bc people who aren't witnesses to Flynn's lies (McCabe and Page) have derogatory evidence against them and DOJ THEMSELVES attest to experience & veracity of Pienkta and Strzok.
Gleeson's argument on falsity is not as strong (IMO), but he DOES point out that DOJ's current stand undermines DOJ's past stance that Flynn was bullied into pleading.
The govt is going to beat up Gleeson on this, citing the DC Circuit.
Gleeson finds the controversy that Sullivan might make broad use of: Flynn says he lied bc of abuse. DOJ says there was no abuse and admits his lies hypothetically.

Not even DC Circuit understood that DOJ said (and Barr agreed under oath) there was no abuse.
Gleeson cites Zelinsky's claim that Barr intervened on Trump's behalf for Stone.
Gleeson uses the phrase Fiona Hill wielded so brutally.
And cites Trump's role in Berman's firing.
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