Haytham, See below for 2ndLt Lindsay's summary of his witness work. Also, 1stSgt Carter's wife is returning from deployment that weekend and he's got some kid issues. He's sort of been an issue since day one. I suggest we either try for VTC (not sure of our capabilities), phone, or just drop him. (Plus, he may have had an affair with GySgt Davis.) You'll see we have availability issues with our local witnesses for the weekend. I think we may have to bring that to the judge's attention. In addition to those below, we'll need to add GySgt Davis. I think Maj Tyler is actually still at OCS, so we could bring him in if you want, but he may hurt, too, in that he's the one who told SSgt Lopez one time to stop running the platoon (but not permanently). They would be the only fact witnesses. 1stSgt Lightle (ret.) was there at OCS and can talk about OCS or be a subject matter expert on being a DI, etc. LtCol Jessup was SSgt Lopez's Bn CO (I think) at MCRD Parris Island. LtCol Shusko (ret.) is an exceptional speaker and is the current deputy director of the Martial Arts Center for Excellence. There are also 2-3 prior enlisted 2ndLts, too, who'd probably come off well because of having done boot camp. I will get more info from 2ndLt Lindsay, who's working on this with me, in the morning. And I'll get you a more complete list. I think we'll be able to add at least 2-3 more to those below after conferring with him again. S/f, Bret A. White Captain, U.S. Marine Corps Defense Counsel Office of the Staff Judge Advocate Marine Corps Base 3250 Catlin Avenue Quantico, VA 22134 Main: 703.784.4615/4628 Direct: 703.784.0405 Fax: 703.784.0259 -----Original Message----- From: Lindsay 2ndLt Scott C Sent: Thursday, July 28, 2011 12:11 To: White Capt Bret A Cc: usmc.esq@gmail.com Subject: RE: SSgt Lopez Witnesses Sir, Here is a breakdown of who I've talked to and their availability. I am going to go through and see if I can get in touch w/ anyone else, a good deal of them are deployed or have been assigned to other duty stations. The following individuals have travel arrangements provided by the government and will be present: 1) SgtMaj Vizcarrando 2) LtCol Jessup The following individuals are local and available as witnesses with the exception of the times in brackets: 1) Major Lina Downing [traveling from 5-7 and 10-13] 2) Capt Theresa Strebel [traveling from 5-7] 3) LtCol Joseph Shushko [Giving guest lecture in NC 6-7] 4) 1stSgt Lightle [unavailable the 6th] Additionally, I talked to the following individuals on the phone who are out of the area and they are willing testify telephonically. 1) Lt. Lenard 2) Lt. Brittany Rogers (regards SSgt Lopez as a mentor and would be willing to come up to testify if on a weekend [in NC]) I will continue to try and contact people today sir. Please let me know if you need anything specific done. Best, Lt Lindsay -----Original Message----- From: White Capt Bret A Sent: Tuesday, July 26, 2011 21:27 To: Lindsay 2ndLt Scott C Subject: SSgt Lopez Witnesses Importance: High 2ndLt Lindsay, I need your assistance in getting SSgt Lopez's character witnesses locked on for her trial. I will copy you on an e-mail to her tasking her to reply to you with some info. Also, I'll be sending you an e-mail or two with names of witnesses for you to contact. First we need to hear back from her. There will be two categories of witnesses: 1. Those who she HAS spoken to already: - simply call them, remind them that she spoke to them, that the trial is coming up 3-10 Aug, that we'd like them available from Sat. 6 Aug - Wed 10 Aug, that we won't need them the WHOLE time, and that they'll need to be in Charlies (military) or business attire (civilians). Tell them that either I or Mr. Faraj, her civilian counsel will follow up with them regarding specifics of their testimony. 2. Those who she HAS NOT spoken to already: - For these folks, it will be the same as above, but with more finessing. I'll talk to you about these after we get SSgt Lopez's response. After you hear from her, give me a call or e-mail and I'll give you more clear instructions. I'm pretty much a zombie right now, so this is probably a little unclear. I'll be on my cell phone 832-755-4046 and my personal e-mail at usmc.esq@gmail.com S/f, Bret A. White Captain, U.S. Marine Corps Defense Counsel Office of the Staff Judge Advocate Marine Corps Base 3250 Catlin Avenue Quantico, VA 22134 Main: 703.784.4615/4628 Direct: 703.784.0405 Fax: 703.784.0259
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