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
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