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RE: Meridith's schedule



I do deserve a TAD to the Crim Law New Dev Course - more than you know...

I was thinking the same thing about CAAF, but I didn't want to count on the circus elephants - circus being the operative word here.

Major Meridith L. Marshall
Senior Defense Counsel
MCAS, Miramar
858-577-1720 (desk line)
dsn 267-1720
858-997-8332 (government cell)
meridith.marshall@usmc.mil 


-----Original Message-----
From: Puckett Neal [mailto:neal@puckettfaraj.com] 
Sent: Friday, August 26, 2011 9:59 AM
To: Marshall Maj Meridith L
Cc: Faraj Haytham
Subject: Re: Meridith's schedule

Don't you deserve a TAD to the Criminal Law New Developments Course?
Besides, the smart money is on us getting a stay from CAAF while they decide the Vokey issue and this may be yet another scheduled trial date that's Overrun By Elephants (OBE).

Neal A. Puckett, Esq
LtCol, USMC (Ret)
Puckett & Faraj, PC
1800 Diagonal Rd, Suite 210
Alexandria, VA 22314
703.706.9566
www.puckettfaraj.com
www.twitter.com/puckettfaraj


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 703-706-9566 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.

On Aug 26, 2011, at 12:54 PM, Marshall Maj Meridith L wrote:

You won't need me there in advance of trial for any reason?


Major Meridith L. Marshall
Senior Defense Counsel
MCAS, Miramar
858-577-1720 (desk line)
dsn 267-1720
858-997-8332 (government cell)
meridith.marshall@usmc.mil 


-----Original Message-----
From: Puckett Neal [mailto:neal@puckettfaraj.com] 
Sent: Friday, August 26, 2011 9:54 AM
To: Marshall Maj Meridith L
Cc: Faraj Haytham
Subject: Meridith's schedule

Totally willing to waive your attendance on 3-4 Nov if that 39a schedule gets approved.  No sweat.  Maybe we just don't bring it up?

Neal A. Puckett, Esq
LtCol, USMC (Ret)
Puckett & Faraj, PC
1800 Diagonal Rd, Suite 210
Alexandria, VA 22314
703.706.9566
www.puckettfaraj.com
www.twitter.com/puckettfaraj


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 703-706-9566 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.

On Aug 26, 2011, at 12:30 PM, Marshall Maj Meridith L wrote:

It's the Crim Law New Dev. Course and it's THE ONLY TAD I get to go on as a field grade.

Of course if we tell Gannon that, my TAD will get shit canned.  :-(

Major Meridith L. Marshall
Senior Defense Counsel
MCAS, Miramar
858-577-1720 (desk line)
dsn 267-1720
858-997-8332 (government cell)
meridith.marshall@usmc.mil 


-----Original Message-----
From: Neal Puckett [mailto:neal@puckettfaraj.com] 
Sent: Friday, August 26, 2011 9:29 AM
To: Marshall Maj Meridith L
Subject: Re: Wuterich Opinion Released

TAD?

Neal A. Puckett, Esq.
LtCol, USMC (Ret)
Senior Partner
Puckett & Faraj, PC
703.706.9566
www.puckettfaraj.com

On Aug 26, 2011, at 12:27, "Marshall Maj Meridith L" <meridith.marshall@usmc.mil> wrote:



Neal, 



I am not going to be available until 7 November.  I will be out of town from 31 October until 6 November.





Major Meridith L. Marshall


Senior Defense Counsel


MCAS, Miramar


858-577-1720 (desk line)


dsn 267-1720


858-997-8332 (government cell)


meridith.marshall@usmc.mil 




-----Original Message-----


From: Puckett Neal [mailto:neal@puckettfaraj.com] 


Sent: Friday, August 26, 2011 8:48 AM


To: Jones LtCol David M


Cc: Gannon Maj Nicholas L; haytham@puckettfaraj.com; Marshall Maj Meridith L; Sullivan LtCol Sean


Subject: Re: Wuterich Opinion Released



Your Honor,


To update the court, Mr. Faraj represents that he'll be available beginning Tues, 25 Oct, but that Thanksgiving weekend has been a huge annual family get-together week since before he was born and he intends to be in Dearborn, MI that week.  I still have to be in Norfolk on the 31st.


We recommend doing preliminary 39a sessions on Thurs/Fri, 3-4 Nov and beginning the trial on 7 Nov.  We're pretty certain this is a 3-week trial, and can be completed before Thanksgiving.  If the government agrees, perhaps this could be a short 802 tonight!


V/r,



Neal A. Puckett, Esq


LtCol, USMC (Ret)


Puckett & Faraj, PC


1800 Diagonal Rd, Suite 210


Alexandria, VA 22314


703.706.9566


www.puckettfaraj.com


www.twitter.com/puckettfaraj




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 703-706-9566 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.



On Aug 26, 2011, at 11:33 AM, Jones LtCol David M wrote:



Thanks all,



For working your schedules for the 802. We'll talk in about 7 hours.



R,



LtCol Jones 


David M. Jones 


Military Judge 


Western Pacific Judicial Circuit 


Navy-Marine Corps Trial Judiciary



________________________________



From: Puckett Neal <neal@puckettfaraj.com> 


To: Jones LtCol David M 


Cc: Gannon Maj Nicholas L; Faraj Haytham <haytham@puckettfaraj.com>; Marshall Maj Meridith L; Sullivan LtCol Sean 


Sent: Fri Aug 26 20:30:43 2011


Subject: Re: Wuterich Opinion Released 




Your Honor,


The court hasn't heard back from the defense because y'all were chatting way past my bedtime last night.  Old people go to bed early.  I can tell you that my Oct calendar is full, including two contested members trials.  One is an Air Force officer GCM beginning 11 Oct and set for 4 days.  That case has already been continued through the Air Force central docketing system.  The Air Force will not continue that case again.  Mr. Faraj and I are both involved.  The other GCM was set by your boss at Quantico for 17-20 Oct, wedging it into an apparently very busy East Coast Navy/Marine Corps docket.  I am set to teach 2 hours during an all-day CLE by the National Business Institute in Norfolk, VA on 31 Oct.  The flyers are already out with my name and bio in them.  I cannot fail to fulfill this formal, written, contractual obligation.  Yes, I signed a contract.


My November and December calendars are clear.  Though we'd request a full week for on-the-ground in CA final prep time before beginning the trial.  I will fill in the calendar with Mr. Faraj's commitments and be ready to discuss scheduling for both of us this evening at 2000.  


V/r,



Neal A. Puckett, Esq


LtCol, USMC (Ret)


Puckett & Faraj, PC


1800 Diagonal Rd, Suite 210


Alexandria, VA 22314


703.706.9566


www.puckettfaraj.com <http://www.puckettfaraj.com/> 


www.twitter.com/puckettfaraj




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 703-706-9566 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.



On Aug 26, 2011, at 7:01 AM, Haytham Faraj wrote:



Your honor,


I am not available at 2000. I will be available tomorrow but I'll be on the west coast. I am not sure of Mr Puckett's availability. 



Haytham Faraj 


Sent from my iPhone



On Aug 26, 2011, at 1:01 AM, "Jones LtCol David  M" <david.m.jones5@usmc.mil> wrote:





 Counsel,  





 I haven't heard anything back from the defense, so I have no idea where you are physically located at.  However, I am ordering an 802 conference for 0800 Saturday, 27 August, Okinawa time.  Since I am 15 hours ahead of PST and 12 hours ahead of EST, this means the 802 conference would be at 1700 PST and 2000 EST, on Friday, 26 August.  If the defense cannot make this time, I need to know immediately and we will postpone the 802 conference exactly 24 hours later.





 I assume that our conference line number is 760-725-8101, as it has been in the past.  Major Gannon, please confirm this.





 Please have your calendars ready.  I am looking at the month of October and will work with all other Court Jurisdictions to assist in clearing your schedules.  As the Appellate Court stated, "Put simply, it is time to place this matter before a trial court for a verdict."   





 R,   





 LtCol David M. Jones




 Military Judge




 Western Pacific Judicial Circuit




 Navy-Marine Corps Trial Judiciary




 Office: 645-7287 / 2156




 Fax: 645-2035




 From the U.S.: 81-611-745-7287 / 2156 






 -----Original Message-----




 From: Gannon Maj Nicholas L 




 Sent: Friday, August 26, 2011 12:03




 To: Jones LtCol David M




 Cc: 'neal@puckettfaraj.com'; 'haytham@puckettfaraj.com'; Marshall Maj Meridith L; Sullivan LtCol Sean




 Subject: Re: Wuterich Opinion Released





 Your Honor,





 The government requests that the Court order an 802 as soon as possible even as soon as tomorrow west coast time.  Given the defense team's unwillingness to talk dates during the  CCA stay, coupled with the governments desire to bring this case to trial, I respectfully request that the Court intervene, and take charge of the scheduling of this case.  





 The TC are available anytime for a scheduling conference.  





 Very respectfully,




 Maj Gannon 





 ----- Original Message -----




 From: Jones LtCol David  M




 To: Gannon Maj Nicholas L




 Cc: 'neal@puckettfaraj.com' <neal@puckettfaraj.com>; 'haytham@puckettfaraj.com' <haytham@puckettfaraj.com>; Marshall Maj Meridith L; Sullivan LtCol Sean




 Sent: Thu Aug 25 19:43:04 2011




 Subject: RE: Wuterich Opinion Released





 Excuse me.  I can also call in tomorrow morning, Saturday my time, which would be Friday evening your time.  Just let me know, I'm quite flexible.





 LtCol David M. Jones




 Military Judge




 Western Pacific Judicial Circuit




 Navy-Marine Corps Trial Judiciary




 Office: 645-7287 / 2156




 Fax: 645-2035




 From the U.S.: 81-611-745-7287 / 2156 






 -----Original Message-----




 From: Gannon Maj Nicholas L 




 Sent: Friday, August 26, 2011 11:08




 To: Jones LtCol David M




 Cc: 'neal@puckettfaraj.com'; 'haytham@puckettfaraj.com'; Marshall Maj Meridith L; Sullivan LtCol Sean




 Subject: Re: Wuterich Opinion Released





 Your Honor,





 The government requests that the Court order an RCM 802 conference as soon as possible.  The TC are available anytime.





 Very respectfully,




 Maj Gannon 





 ----- Original Message -----




 From: Jones LtCol David  M




 To: Gannon Maj Nicholas L




 Cc: Neal Puckett <neal@puckettfaraj.com>; Haytham Faraj <haytham@puckettfaraj.com>; Marshall Maj Meridith L; Sullivan LtCol Sean




 Sent: Thu Aug 25 18:53:40 2011




 Subject: RE: Wuterich Opinion Released





 Counsel,





 Major Gannon, thank you.  With the stay lifted, I am looking to set a trial schedule with all parties as soon as possible.  As everyone is aware, we need to block out one month's time very soon as there are so many different schedules we are trying to coordinate.  Is this something you can do on your own or do you need my intervention via an 802?  





 R,





 LtCol David M. Jones




 Military Judge




 Western Pacific Judicial Circuit




 Navy-Marine Corps Trial Judiciary




 Office: 645-7287 / 2156




 Fax: 645-2035




 From the U.S.: 81-611-745-7287 / 2156 






 -----Original Message-----




 From: Gannon Maj Nicholas L 




 Sent: Friday, August 26, 2011 3:09




 To: Jones LtCol David M




 Cc: Neal Puckett; Haytham Faraj; Marshall Maj Meridith L




 Subject: Wuterich Opinion Released





 Your Honor,





 The Wuterich Opinion has been issued by the CCA.  I have attached a copy Sir.





 Very respectfully,




 Maj Gannon









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