Good morning Gentlemen, I spoke to Jeremy Owens this morning, and there are two things I want to inform you of. First: He has a family vacation planned for 1 Nov-15 Nov. I know that the concerns of the defense having the in person testimony of the witness prevail, but I wanted to let you both know that Mr. Owens inquired about being able to testify telephonically. I informed him that such a decision would not be up to me, and if the defense wanted him here, then he comes here. Additionally, I told him that I would work with the defense as practicable to avoid imposing on his family vacation to the extent it is possible. I would imagine that Mr. Owens would not be a witness until at least the second day of trial (15 Nov) so perhaps we could simply have him fly here to Quantico as opposed to back home on the last day of his vacation. Second: He and I discussed the rest of what took place on 28 August. He indicates that everything that took place was consensual, and that Ms. Klay in fact took the first move toward him. Now, Col Riley has indicated that he is not inclined to grant a deposition on government request, but perhaps he may if the defense requests one. Furthermore, now that we know what Mr. Owens will testify to, I think that this is sufficient to tender a PTA for the General's consideration. 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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