re: Durham obtains recordings of halper saying "flynn is fricked", 2 days before illegal leak

Rule 48(a) of the Federal Rules of Criminal Procedure: As Thomas Ward Frampton explains in the Stanford Law Review, the committee tasked with drafting the federal rules “focused on the possibility that improper political influence might spur a prosecutor’s decision to drop a case.” Ultimately, the Supreme Court adopted the requirement currently found in Rule 48(a) — that the government obtain “leave of court” for a dismissal. That change, as Frampton observes, “armed the district judge with a powerful tool to halt corrupt or politically motivated dismissals of cases."

Saw this online today.. any lawyers out there know if this is in play?