Neal, I still need to do a bit of massaging on the motion and incorporate Haytham’s suggestions – which I’ll do over my lunch hour – but the most basic question is whether you think we should file it. After finishing the first draft last night, I’m much more strongly of the opinion that we SHOULD, but I’ll certainly defer to you if you’re concerned that it might antagonize Erickson and if you’re reluctant to do so. Maj Sip, if Neal wants to file this, would you please alert Brian Keller and Maj Kirby to see if the government will consent. I’m sure they won’t, but I want to make sure we’re complying scrupulously with NMCCA’s rules. Semper Fi, Dwight H. Sullivan Senior Appellate Defense Counsel Air Force Appellate Defense Division (AFLOA/JAJA) 1500 West Perimeter Road, Suite 1100 Joint Base Andrews, MD 20762 240-612-4773 DSN: 612-4773 Fax: 240-612-5818 |