Doug, I edited your request. I added everyone I could think of along with a synopsis of what they would say. Witnesses in bold are my top choices. On Tue, Feb 1, 2011 at 1:01 PM, Douglas Wacker <douglas.wacker@gmail.com> wrote: > We also need to request judge to compel discovery of investigation records. > > -dsw > > On Feb 1, 2011 12:53 PM, "Douglas Wacker" <douglas.wacker@gmail.com> wrote: >> Haytham, >> >> Here is the list of individuals who have been involved in the case. >> >> The issues I see: >> --Misconduct in investigation and interference with potential witnesses: >> Blosser, Brooder, Easley, USD Officials. >> --Interference with ELP Law status and contact with Col Helfrich, SJA to >> CMC >> Officials. >> --PAO news release, how it was unheard of (Steve Liewer), and its >> distribution to every person on MCRD on three separate days. >> --LtCol Bond Email and Col Smith statements to G-3 and other personnel; >> transfer to H&S Bn S-3 (to a position never filled before under Maj >> Goodpasture) after exercise completion. >> --Transfer to 3d MAW and ultimate delay in case process in order to avoid >> UCI, discussions had to be held at the General or CoS level with SJAs and >> staff involved. >> ***A transfer to avoid litigating the issue of UCI is wrongful, see J. >> Effron dissent in U.S. v. Villareal (CAAF 1999). >> >> You should be able to link the individuals to the different issues. I >> expect >> Col Smith and SA Burge to deny, deny, deny. The other individuals will be >> able to testify as to what actions/statements were taken by Col Smith and >> SA >> Burge. >> >> Col White and Capt Pappas were the SJA and officer responsible with filing >> the ODM matter when this started in Jan 2008 with a phone call from >> another >> NCIS agent to Col Helfrich and Capt Woelhoff alerting me to the arrest >> warrant in NOLA. >> >> S/F >> >> Doug >> >> >> >> -- >> Douglas S. Wacker >> 1719 Adams Ave >> San Diego, CA 92116 >> 858.401.9392 > -- Christian P. Hur
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UCI motion witnesses requested.doc
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