Haytham, Just tried calling, but I guess you're still in the Art 32. Hope it's going well. I'm working my way through the Art 32 transcript for Rowe - amazing stuff. I've got a conference call at 1800 with all the RDCs, but would like to speak with you, if possible, when you get a second or two before I call Rowe this evening. Thanks! Russ -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, November 09, 2011 10:34 To: Shinn Capt Scott R Subject: Re: Rowe motions Let me get back to you later. I'm about to start an article 32. I trust your judgement. I prefer we get a pleading filed as soon as practicable to be fair. We can always adjust. Haytham Faraj Sent from my iPhone On Nov 9, 2011, at 7:04 AM, "Shinn Capt Scott R" <scott.shinn@usmc.mil> wrote: > Haytham, > Here's what I'm thinking... > > For the Multiplicity Argument: > > - Charge I Spec 5 mult. w/ Charge I Spec 1 > - Charge I Spec 2 mult. w/ Charge II > - Charge II Spec 1 mult. w/ Charge II Spec 2 > - Charge IV mult. w/ Charge VII Spec 3 and Add'tl Charge Spec 2 > - Charge V mult. w/ Charge I > - Charge VI mult w/ Charge VII Spec 1 > > > For the UMC Argument: > > Charge I Spec 4 (indecent act) as the umbrella offense for: > - Charge I Specs 1, 2, 3, and 5 > - Charge III > - Charge V > - Charge VI > - Charge VII Specs 1 and 4 > - Add'l Charge Spec 2 > > Charge III Spec 1 is the umbrella for Spec 2 > > Add'l Charge Spec 2 is the umbrella offense for Charge IV > > > What do you think? > > ~Russ > > > -----Original Message----- > From: Haytham Faraj [mailto:haytham@puckettfaraj.com] > Sent: Tuesday, November 08, 2011 20:01 > To: Shinn Capt Scott R > Subject: Rowe motions > > Russ, > > I would like you to take a close look at the charge sheet and draft a motion to challenge multiplicity and UMC. I think there are a lot of multiplicious charges or unfair multiplication of charges. We should be able to kill a few of those before trial. > > > > Thanks >
Attachment:
smime.p7s
Description: S/MIME cryptographic signature