Haytham, I called and left a message on your cell. I just received the attached from Capt Combe. He said we can cancel the Depo for this week if there is a reason. That would probably be best because due to the short notice Jim is not really keen on coming tomorrow and you are presumably not available this week. Capt Combe seems amicable to rescheduling the depo but doing so will blow his 15th deadline. Not necessarily a consequence to us, but he will have to get a new deadline from the MCCDC SJA. As for why we want the depo, since the Govt is obviously not keen on the written statement that Jeremy provided, I thought that we wanted to get his story out in order for the CA to buy off on it and drop the charges and allow Jim to resign. From what TC is saying, the CA will not deal with Jim until he is satisfied with Owens' side of the story (despite the fact that Klay is not credible). Capt Combe and I did discuss the fact that b/c she is not credible, what is the difference what Jeremy testifies to as long as it does not corroborate Klay's version. He agreed and said that he would ask the Mojo to address that to the CA. But for right now they want to go forward with the deposition. By the way, not sure if you knew, but Klay is now completely out of the Marine Corps and is no longer represented by Govt counsel. s/f Matt -----Original Message----- From: Combe Capt Peter C Sent: Tuesday, September 13, 2011 14:26 To: Mcconnell Major Matthew N; HAYTHAM@PUCKETTFARAJ.COM Cc: Contreras Capt Antonio M Subject: Jeremy Owens Deposition Gentlemen, Attached is notice of Thursday's Deposition of Mr. Jeremy Owens. As for the place, we will be in the upstairs court room here at LeJeune Hall as it is open. 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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