[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]

RE: IE NUMBER 61 ICO CAPTAIN WACKER



Capt Hur, please see my response that I just sent and wait for ruling by the IO

thanks 


LtCol Sean M. Sullivan, USMCR
Senior Trial Counsel, MARCENT
Legal Services Support Section
1st Marine Logistics Group
Box 555067, Camp Pendleton, CA 92055-5607
Comm: (760) 763-9904/9902/9900
DSN: 361-9904 Fax: (760) 763-9901

Classification: UNCLASSIFIED//LIMDIS
This e-mail is FOR OFFICIAL USE ONLY and is exempt from mandatory disclosure under FOIA. DoD 5400.7R, "DoD Freedom of Information Act Program", DoD Directive 5230.9, "Clearance of DoD Information for Public Release", and DoD Instruction 5230.29,  and "Security and Policy Review of DoD Information for Public Release".
ATTORNEY-CLIENT PRIVILEGED COMMUNICATION OR ATTORNEY WORK PRODUCT. The information contained in this message is privileged. It is intended only to be read by the individual or entity addressed or their designee. If the reader of this message is not the intended recipient, you are on notice that any distribution of this message, in any form, is prohibited. If you have received this message in error, please immediately notify the sender and delete or destroy any copy of this message.





-----Original Message-----
From: Hur Capt Christian P 
Sent: Monday, April 19, 2010 2:21 PM
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Sounds good Sir.  Thank you. 


Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego, CA 92140

This email may contain Attorney Work Product.  Please delete if you received this message in error. 
 
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 14:16
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Lets do this then, I will not add an IE 61 at this time.  If you find a discrepancies or other section you want to highlight for my consideration, literally do that and provide it to me for what I will add as IE61.  For instance if you find something you want me to take note of on page 14 - pull that particular page, highlight it with a marker (or circle it) and make that the first page of IE61, and so on and so on.

Does this make sense to everyone? 

-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 14:07
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Sir,

We will add any analysis of those notes to our argument due on Friday Sir.  There were no major discrepancies noted by the defense between the hand written notes and the summaries of interviews.

Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego, CA 92140

This email may contain Attorney Work Product.  Please delete if you received this message in error. 
 
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 13:59
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Gentlemen:

This is a 161 pages.  Is the defense submitting that I need to read this or do they summarize their points adequately in their summations of the ROIs previously submitted?  Alternatively, does the Government object if the defense submits an alternate exhibit - (61) - where they summarize what they feel is important for me to consider from what they read in the notes?

If either side prefers I read this in its entirety - I will.

s/f

LtCol Sayegh   

-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 13:38
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Sir,

I believe the attached contains most if not all of the notes. 


Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego, CA 92140

This email may contain Attorney Work Product.  Please delete if you received this message in error. 
 
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 13:36
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Can someone send those to me please? 

-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 11:44
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Sir,

61 was the handwritten notes of the NCIS agent that the defense received via email from the trial counsel. 


Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego, CA 92140

This email may contain Attorney Work Product.  Please delete if you received this message in error. 
 
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 11:02
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Subject: IE NUMBER 61 ICO CAPTAIN WACKER

Gents:

In gathering the IEs, I could not find an IE 61.  I have IE 60 as the email from Lovette Robinson and then pick up with the statements of Cook and Barker as 62 and 63 respectively.  Please confirm that is an admin oversight as opposed to me not having something.

thanks.

s/f

LtCol Sayegh 

 

Attachment: smime.p7s
Description: S/MIME cryptographic signature