Neal and Haytham, I got a voicemail from Nick Kadlec and we need to get your social security numbers to get you in the Defense Travel System database so that if the trial is moved on short notoce they can set up your travel to Iraq. If you don't mind doing it over email, I will walk them up to Kadlec. If not, you can call me at work (757 44 4791) or my cell (845 642 1889) and I will pass along. Thanks. V/r Kevin -----Original Message----- From: Anastos, Kristen LT NLSO, MIDLANT Sent: Tuesday, March 23, 2010 17:48 To: Neal Puckett; Shea, Kevin D LT NLSO, MIDLANT; Faraj Haytham Subject: RE: U.S. v. KEEFE -- FILING: GOV'T MOTION FOR DEPOSITION (8 MAR 10) Mr. Puckett: We did inform the Government and the MJ that we have no objection to the taking of the deposition. I will draft a reply now, to cement the issue. V/r Kristen CONFIDENTIALITY NOTICE The information contained in this e-mail and accompanying attachments constitute confidential information that may be legally privileged. If you are not the intended recipient of this information, any disclosure, copying, distribution, or the taking of any action in reliance on this information is strictly prohibited. If you received this e-mail in error, please notify me immediately by return e-mail or by calling (757) 444-3597. E-mail communication on the Internet may NOT be secure. There is a risk that this confidential communication may be intercepted illegally. There may also be a risk of waiving attorney-client and/or work product privileges that may attach to this communication. DO NOT forward this message to any third party. If you have any questions regarding this notice, please contact the sender. -----Original Message----- From: Neal Puckett [mailto:neal@puckettfaraj.com] Sent: Tuesday, March 23, 2010 14:46 To: Shea, Kevin D LT NLSO, MIDLANT; Anastos, Kristen LT NLSO, MIDLANT; Faraj Haytham Subject: Fwd: U.S. v. KEEFE -- FILING: GOV'T MOTION FOR DEPOSITION (8 MAR 10) Gang, I thought I had asked one of you to file a one- liner reply indicating no opposition. If I did not, can we put that in? Neal A. Puckett LtCol, USMC (Ret) Puckett & Faraj, PC Sent from my iPhone Begin forwarded message: From: "Modzelewski, Moira D CAPT NAVMARTRIJUD, CENTRAL JUDICIAL CIRCUIT" <moira.modzelewski@navy.mil> Date: March 23, 2010 10:15:10 AM PDT To: "Kadlec, Nicholas J LT RLSO MIDLANT, Norfolk" <nicholas.kadlec@navy.mil>, "CENTRAL CIRCUIT CLERK OF COURT" <CENTRAL_CIRCUIT_CLERK_OF_COURT@navy.mil> Cc: "Cook, Karla R LNC JUDACT, NORFOLK" <karla.cook@navy.mil>, "Neal Puckett" <Neal@puckettfaraj.com>, "Faraj Haytham" <haytham@puckettfaraj.com>, "Shea, Kevin D LT NLSO, MIDLANT" <kevin.d.shea1@navy.mil>, "Anastos, Kristen LT NLSO, MIDLANT" <kristen.anastos@navy.mil>, "Grover, Jason S LCDR RLSO MIDLANT, NORFOLK" <jason.grover@navy.mil>, "Haefner, Erin R LT RLSO, MIDLANT" <erin.haefner@navy.mil>, "Bradbury, Lakin LN2 RLSO MIDLANT, Norfolk" <lakin.bradbury@navy.mil> Subject: RE: U.S. v. KEEFE -- FILING: GOV'T MOTION FOR DEPOSITION (8 MAR 10) Counsel: We need to schedule an 802 on subject motion, with a view to scheduling a 39a if necessary. I have not received the defense response, but was advised yesterday at docket call that 1) the defense does not object to the deposition, but 2) would object to the admission of the deposition at trial. In the interests of judicial efficiency, I am reluctant to forge ahead with an order for a deposition in Baghdad with CDR Carlos as deposition officer absent a resolution of whether the deposition is ultimately admissible at trial. If the deposition were not ultimately admissible at trial, it appears to me possible that this case may be tried in Baghdad if either side seeks the alleged victim's testimony. If this case is going to be tried in Baghdad, we need to know that now, rather than later. TC: Please coordinate a time as soon as possible this week that we can have a telephonic 802 to resolve the way ahead. I am available this week with these exceptions. Wednesday: unavailabe from 1300-1400 EDT. Thursday: I'm traveling to DC for classified document review in my OMC case, and will be on the road from 0630-0930 and again from 1400-1700. Other than that, my schedule is flexible while I'm there. Look forward to talking to you sometime shortly, r/ Moira Modzelewski CAPT, JAGC, USN Circuit Judge Navy-Marine Corps Trial Judiciary Central Circuit Norfolk, VA 757-444-3733 DSN 564-3733 -----Original Message----- From: Kadlec, Nicholas J LT RLSO MIDLANT, Norfolk Sent: Monday, March 08, 2010 15:28 To: CENTRAL CIRCUIT CLERK OF COURT Cc: Cook, Karla R LNC JUDACT, NORFOLK; Lemons, Sabrina M HT2 NLSO; Veit, Sandy A LNC RLSO MIDLANT, Norfolk; Modzelewski, Moira D CAPT NAVMARTRIJUD, CENTRAL JUDICIAL CIRCUIT; 'Neal Puckett'; Faraj Haytham; Shea, Kevin D LT NLSO, MIDLANT; Anastos, Kristen LT NLSO, MIDLANT; Grover, Jason S LCDR RLSO MIDLANT, NORFOLK; Haefner, Erin R LT RLSO, MIDLANT; Bradbury, Lakin LN2 RLSO MIDLANT, Norfolk Subject: U.S. v. KEEFE -- FILING: GOV'T MOTION FOR DEPOSITION (8 MAR 10) Chief Cook: Good afternoon. Attached for filing, please find a government motion for deposition (with enclosures and proposed order). The signed originals have been delivered to your office. Thank you. R, Nicholas J. Kadlec LT, JAGC, USN Trial Counsel Region Legal Service Office Mid-Atlantic 9620 Maryland Ave, Suite 201 Norfolk, VA 23511-2939 Comm: 757-444-5201 DSN: 564-5201 SIPR: <mailto:nicholas.kadlec@navy.smil.mil> nicholas.kadlec@navy.smil.mil **FOR OFFICIAL USE ONLY/PRIVACY SENSITIVE/PRIVILEGED** This e-mail message and any attachments are intended only for the person or entity to which they are addressed and contains confidential and/or privileged material protected by the attorney-client relationship and/or work-product rule. Any unauthorized review, use, disclosure, or distribution is prohibited and can result in both civil and criminal penalties. If you are not the intended recipient, please contact the sender by reply e-mail, or by telephone at 757-444-5201, and destroy all copies of the original message.
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