Capt Combe, Thanks! S. Russell Shinn Captain, US Marine Corps Officer-in-Charge Defense Counsel Assistance Program Marine Corps Defense Services Organization 703.614.0885 (w) 703.470.0671 (c) "Marines Defending Marines" -----Original Message----- From: Combe Capt Peter C Sent: Thursday, November 17, 2011 7:40 To: Haytham Faraj Cc: Shinn Capt Scott R Subject: RE: US v. Rowe Motion Mr. Faraj, Roger that Sir. Capt Shinn, Motion attached. Part 1 is the motion and first portion of a transcript of the phone call. Part 2 is the remainder of the transcript. If you need that let me know. Very Respectfully, Capt Peter C. Combe II Trial Counsel Office of the SJA, MCB Quantico 3250 Catlin Ave. Quantico, VA 22134 Comm: (703) 784-0037 DSN: 278 Fax: (703) 784-0035 DSN: 278 -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Thursday, November 17, 2011 7:36 To: Combe Capt Peter C Cc: Shinn Capt Scott R Subject: Re: US v. Rowe Motion I will not object to you preadmitting the phone call. Haytham Faraj Sent from my iPad On Nov 17, 2011, at 7:31 AM, "Combe Capt Peter C" <peter.combe@usmc.mil> wrote: > Mr. Faraj, > > I had intended to have Mrs. Klay and SA Buckmon here for the motion tomorrow to preadmit the recorded phone call. Based on your email below I don't believe that is necessary. If you plan not to contest, then I will tell them that there is no need to come in. Thanks for your cooperation on this. > > Very Respectfully, > Capt Peter C. Combe II > Trial Counsel > Office of the SJA, MCB Quantico > 3250 Catlin Ave. > Quantico, VA 22134 > > Comm: (703) 784-0037 DSN: 278 > Fax: (703) 784-0035 DSN: 278 > > -----Original Message----- > From: Haytham Faraj [mailto:haytham@puckettfaraj.com] > Sent: Thursday, November 10, 2011 12:47 > To: Combe Capt Peter C > Cc: Shinn Capt Scott R > Subject: RE: US v. Rowe Motion > > Pete, > We will not object to your motion. For future reference, feel free to > check with me before working on a motion. If it is not objectionable > I will not object or will try to work with you. With respect to this > motion, I request that the Government also produce the side > conversation that was taking place between the NCIS Agent and Klay while this recording was taking place. > > Vr, > Haytham > > -----Original Message----- > From: Combe Capt Peter C [mailto:peter.combe@usmc.mil] > Sent: Thursday, November 10, 2011 12:27 PM > To: Hale LtCol Charles C > Cc: haytham@puckettfaraj.com; jeffrey.hoey@navy.mil > Subject: US v. Rowe Motion > > Good afternoon Sir, > > Attached is a government motion to preadmit in Rowe. I have already > provided the original to the court reporters to be marked as an > appellate exhibit. > > I know that this government motion is out of time per the original > pretrial order. That said, I understood Monday's 802 conference > established that both defense as well as government motions would be due today. > > If that is not the case, I apologize for my misunderstanding. > > Very Respectfully, > Peter C. Combe II > Capt, U.S. Marine Corps > Trial Counsel > > Office of the Staff Judge Advocate > Military Justice Office > Marine Corps Base Quantico > 3250 Catlin Avenue > Quantico, VA 22134 > > Comm: (703) 784-0037 DSN: 278 > Fax: (703) 784-0035 DSN: 278 > > NOTICE: This electronic transmission contains privacy sensitive > information, attorney work-product or information protected under the > attorney-client privilege. It is confidential, legally privileged and > intended for use only by the individual or entity which is entitled to > receive this transmission for official use only. Any misuse or > unauthorized access is strictly prohibited and may result in both > civil and criminal penalties. Do not release this information without > prior authorization from the sender. If this has inadvertently > reached the wrong party, please delete all materials pertaining to it > immediately and notify the sender at the email address or phone number > above. This electronic transmission is also not intended by the > sender or the agency to constitute either an electronic record, or an > electronic signature, or to constitute any agreement by the sender to conduct a transaction by electronic means. > > >
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