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RE: Defense motion for continuance



Your Honor,

Good Morning Sir.  

The government is prepared to proceed on 30 November 2011 if the Military Judge denies the Defense continuance request.

However, after consultations, if the defense commits to an early January trial date and acknowledges that all delay is attributable to the defense (as it appears they have done in their pleading of 7 October 2011) then the government does not oppose this continuance request.

The government opposes any continuance request that goes beyond January 2012.

I am available for an 802 should the Military Judge so desire.  

Very respectfully submitted, 
Maj Gannon  

-----Original Message-----
From: Jones LtCol David M 
Sent: Sunday, October 09, 2011 2:38
To: 'haytham@puckettfaraj.com'
Cc: Gannon Maj Nicholas L; Sullivan LtCol Sean; 'neal@puckettfaraj.com'; 'bethany@puckettfaraj.com'
Subject: Re: Defense motion for continuance

Government,

Are you opposing this or not?

R,

LtCol Jones 
David M. Jones 
Military Judge 
Western Pacific Judicial Circuit 
Navy-Marine Corps Trial Judiciary

________________________________

From: Haytham Faraj <haytham@puckettfaraj.com> 
To: Jones LtCol David M 
Cc: Gannon Maj Nicholas L; Sullivan LtCol Sean; 'Puckett Neal' <neal@puckettfaraj.com>; 'Trujillo Bethany' <bethany@puckettfaraj.com> 
Sent: Sat Oct 08 08:29:23 2011
Subject: Defense motion for continuance 



Your honor,

The attached is a motion for a defense continuance.  We are prepared to have an 802 to discuss should you desire.

 

Vr,

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

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