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FW: Jeremy Owens Deposition



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

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Attachment: OWENS_DEPO_NOTICE.pdf
Description: Adobe PDF document

Attachment: smime.p7s
Description: S/MIME cryptographic signature