Haytham, Got it, I found the e-mail that I sent to Judge Hale and TC back in Sept (I just sent that to you via separate correspondence.) I didn't request an expert. I noticed that you mentioned it on your proposed dates e-mail, but what type of expert are we going to request? Psychiatrist for Klay? Since Page 56 matters are now due on the 7th, what witnesses will we be calling? I'll prepare the list if you would like, but we just need to sort out who that will be. On the merits: Klay, Owens, Brick, Cpl Gillespie, Cpl Quinn, Klay's husband? Anyone else? On potential sentencing: Not sure who you (or Jim) would want here. Anyway, let me know. Thanks Haytham, s/f Matt -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, October 26, 2011 12:30 To: Mcconnell Major Matthew N Subject: RE: Rowe reasons for the continuance Matt, That was filed on the day of the arraignment or shortly thereafter. Would you please send me information about the expert that you requested? What is the status of witness requests? -----Original Message----- From: Mcconnell Major Matthew N [mailto:matthew.n.mcconnell@usmc.mil] Sent: Wednesday, October 26, 2011 11:12 AM To: Haytham Faraj Subject: RE: Rowe reasons for the continuance Haytham, I'll be there as well. Just as a reminder, you still need to submit your Notice of Appearance with the court. The Govt. may bring that up at the 802, but if you present it before hand, it shouldn't be an issue. v/r Matt -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Wednesday, October 26, 2011 11:01 To: Combe Capt Peter C; Hoover Capt Christopher M Cc: Mcconnell Major Matthew N Subject: RE: Rowe reasons for the continuance I am available today at 1400. Thank you for coordinating. -----Original Message----- From: Combe Capt Peter C [mailto:peter.combe@usmc.mil] Sent: Wednesday, October 26, 2011 10:59 AM To: Haytham Faraj; Hoover Capt Christopher M Cc: Mcconnell Major Matthew N Subject: RE: Rowe reasons for the continuance Mr. Faraj, The Military Judge is available for an 802 at 1400. 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: Tuesday, October 25, 2011 17:51 To: Hoover Capt Christopher M Cc: Mcconnell Major Matthew N; Combe Capt Peter C Subject: RE: Rowe reasons for the continuance I am available by telephone. -----Original Message----- From: Hoover Capt Christopher M [mailto:christopher.hoover@usmc.mil] Sent: Tuesday, October 25, 2011 5:28 PM To: Haytham Faraj Cc: Mcconnell Major Matthew N; Combe Capt Peter C Subject: RE: Rowe reasons for the continuance I didn't expect that you would. Once you file, we will ask for a 802 with the judge tomorrow in hopes to litigate the motion and get new dates. I don't think we need to have a 39(a) to resolve this issue. Are you going to be available tomorrow? Captain Christopher M. Hoover Military Justice Officer Marine Corps Base Quantico (703) 432-0488 (office) (603) 809-5781 (cell) -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Tuesday, October 25, 2011 17:03 To: Hoover Capt Christopher M Cc: Mcconnell Major Matthew N; Combe Capt Peter C Subject: RE: Rowe reasons for the continuance Chris, Unfortunately, I cannot accept that. Thank you. I'll file my motion tomorrow. -----Original Message----- From: Hoover Capt Christopher M [mailto:christopher.hoover@usmc.mil] Sent: Tuesday, October 25, 2011 4:27 PM To: Haytham Faraj Cc: Mcconnell Major Matthew N; Combe Capt Peter C Subject: RE: Rowe reasons for the continuance Mr. Faraj, CG would allow us to join a continuance motion if it was judge alone. Given the fact that the CG is selecting members, he is not inclined to allow us to join a motion to continue at this late juncture. If members were not a factor, then he would not have issue with the continuance. Captain Christopher M. Hoover Military Justice Officer Marine Corps Base Quantico (703) 432-0488 (office) (603) 809-5781 (cell) -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Monday, October 24, 2011 17:37 To: Combe Capt Peter C; Hoover Capt Christopher M Cc: Mcconnell Major Matthew N Subject: Rowe reasons for the continuance Gentlemen, I am writing to request concurrence for a continuance of the Rowe trial. The trial is currently scheduled to commence on November 1. I am requesting that it be continued until March 5, 2012. The primary purpose for the lengthy delay is because I am scheduled to for the U.S. v. Wuterich trial from January 4 until January 31, 2012. U.S. v. Wuterich is a case that resulted from the killings of 24 civilians in the town of Haditha in Iraq on November 19, 2005. That case has languished due to lengthy appellate matters that were recently resolved. The gravity of the charges in that case and its age require me to invest substantial time to get ready. Our firm has, therefore, set aside the month of December to prepare. I previously notified Trial Counsel that I would be agreeable to a date in November. I am currently available the week of November 14 and the week of November 28. While the November dates I proposed are agreeable, I request that you keep in mind our request to immunize Mr. Owens and our request for an expert. So long as those two matters can be accomplished, I will be available during the two proposed November dates. The defense will agree that the delay will be excludable. Thank you for consideration of my request Vr, Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC 835 Mason Street Suite 150-A Dearborn, MI 48124 313-457-1390 Phone 202-280-1039 Fax www.puckettfaraj.com <http://www.puckettfaraj.com/> The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution.
Attachment:
smime.p7s
Description: S/MIME cryptographic signature