Mr. Faraj, I know this is sort of a formality, but the government will oppose any request for continuance so the defense will have to file something with the court, and we'll go from there. 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: Monday, October 24, 2011 10:31 To: Combe Capt Peter C Cc: Mcconnell Major Matthew N Subject: RE: US v. Rowe Ok. Please let me know but the sooner the better. -----Original Message----- From: Combe Capt Peter C [mailto:peter.combe@usmc.mil] Sent: Friday, October 21, 2011 2:52 PM To: Haytham Faraj Cc: Mcconnell Major Matthew N Subject: RE: US v. Rowe Mr. Faraj, I will not still be on the case at that time. I am scheduled to move to the defense section next month. I will speak with Capt Hoover and see who he would detail if the trial is in March and what he feels about those dates. I know that he has expressed the opinion that he wants this case to go sooner rather than later, but I agree there are some fairly significant hurdles to that. 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: Friday, October 21, 2011 13:35 To: Combe Capt Peter C Cc: Mcconnell Major Matthew N Subject: RE: US v. Rowe Gentlemen, Here are my proposed dates: Trial to start on March 5, 2012 All discovery and notices pursuant to RCM 701, 301, 304, 311, 321, 413(b), and 414(b) due on January 4 2012 Request for Defense expert January 9, 2012 Witness request February 13, 2012 Motions due February 6, 2012 Article 39a February 21, 2012 Page 56 matter due February 24, 2012 The purpose of the date in March is because I am scheduled to be in the Haditha trial from January 4-31. The entire month of December will be dedicated to preparing for that case. While the month of November has some white space for me, I don't think either side will realistically be ready for trial given the continued work on Mr. Owens and some of the other logistical matters that remain to be done. I am open to discussing it, however. Vr, Haytham Faraj -----Original Message----- From: Combe Capt Peter C [mailto:peter.combe@usmc.mil] Sent: Thursday, October 20, 2011 12:00 PM To: Haytham Faraj Subject: RE: US v. Rowe Good afternoon Sir, I was looking to call you but don't have a phone number. I was curious as to whether you were looking at new trial dates, etc. I am asking because we are looking at setting up travel and what-not and would like like to know about new dates before we do so. Thanks for your time, 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: Wednesday, October 19, 2011 9:14 To: Mcconnell Major Matthew N Cc: Combe Capt Peter C Subject: Re: US v. Rowe I have some new proposed dates I will send you today. Haytham Faraj Sent from my iPhone On Oct 18, 2011, at 4:29 PM, "Mcconnell Major Matthew N" <matthew.n.mcconnell@usmc.mil> wrote: > Pete, > > Understand. What about Jeremy? Has he been granted testimonial immunity at this point? If so, are you going to ask for another deposition? > > s/f > Maj McConnell > > -----Original Message----- > From: Combe Capt Peter C > Sent: Tuesday, October 18, 2011 7:53 > To: haytham@puckettfaraj.com; Mcconnell Major Matthew N > Subject: US v. Rowe > Importance: High > > Gentlemen, > > Attached is notice that the government is in the process of contracting an expert in the field of forensic psychology. > > My apologies for the late notice. The government will not oppose any motion raised by this action on grounds of timeliness, but reserves the right to contest any motion on any other grounds. > > 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 > > 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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