UNITED STATES OF AMERICA

V.

MICHAEL T. FLYNN

Criminal No.:

Violation: 18 U.S.C. 1001 (False Statements)

Information

The Special Counsel informs the Court:

Count One (False Statements)

On or about January 24, 2017, defendant MICHAEL T. FLYNN did willfully and knowingly make materially false, fictitious, and fraudulent statements and representations in a matter within the jurisdiction of the executive branch of the Government of the United States, to wit, the defendant falsely stated and represented to agents of the Federal Bureau of Investigation, in Washington, D.C., that:

(i) On or about December 29, 2016, FLYNN did not ask the Government of Russia’s Ambassador to the United States (“Russian Ambassador”) to refrain from escalating the situation in response to sanctions that the United States had imposed against Russia that same day; and FLYNN did not recall the Russian Ambassador subsequently telling him that Russia had chosen to moderate its response to those sanctions as a result of his request; and

(ii) On or about December 22, 2016, FLYNN did not ask the Russian Ambassador to delay the vote on or defeat a pending United Nations Security Council resolution; and that the Russian Ambassador subsequently never described_to FLYNN Russia’s response to his request.

(Title 18, United States Code, Section 1001(a)(2))

ROBERT S. MUELLER, III