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RE: US v. Rowe Motion



Pete,
  Can you forward me the motion for my records?  I wasn't on the original distro.

Thanks!

S/F


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"

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-----Original Message-----
From: Combe Capt Peter C 
Sent: Thursday, November 17, 2011 7:32
To: Haytham Faraj
Cc: Shinn Capt Scott R
Subject: RE: US v. Rowe Motion

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

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