Neal,
I still need to do a bit of massaging on the motion and incorporate Haythamâs suggestions â which Iâll do over my lunch hour â but the most basic question is whether you think we should file it. After finishing the first draft last night, Iâm much more strongly of the opinion that we SHOULD, but Iâll certainly defer to you if youâre concerned that it might antagonize Erickson and if youâre 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. Iâm sure they wonât, but I want to make sure weâre complying scrupulously with NMCCAâs rules.
Semper Fi,
DHS
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