|
Thanks, Neal! Very helpful. I'll work that into the
interrogatory motion and then we can decide whether we want to file it or
not.
Semper Fi,
DHS
In a message dated 6/8/2011 9:17:31 P.M. Eastern Daylight Time,
neal@puckettfaraj.com writes:
All,
Long meeting with LtCol Erickson. Bottom line is that as the LSSS
OIC, he has not been asked and does not plan to re-enter the Wuterich case as
TC or Asst TC. He continues to be a resource, of course, as he made TWO
trips over there for the investigation. The second was to do the
depositions.
S/f,
Neal
Neal A. Puckett,
Esq
LtCol, USMC (Ret)
Puckett & Faraj, PC
1800 Diagonal Rd, Suite
210
Alexandria, VA 22314
703.706.9566
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 888-970-0005 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 Jun 8, 2011, at 9:35 AM, Sullivan, Dwight H CIV USAF AFLOA/JAJA
wrote:
I just spoke with Neal. For tactical reasons, we want to hold off
on filing the motion for interrogatories until at least tomorrow. So
I'll finish that up and circulate it tonight.
Now that the government
and Jones have filed everything required by NMCCA's order, the ball is in our
court. But it will be difficult for us to advance that ball (at the risk
of mixing metaphors) until NMCCA has ruled on our motion for access to the
sealed materials. To let NMCCA know what we're doing, my current thought
is that we should file a motion to provide NMCCA with a situation report
tomorrow telling them where we see the case now and where we see it going.
I'll draft and circulate something tonight. (I had been planning
to use our opposition to the government's motion to lift the stay as a vehicle
for providing a SitRep to NMCCA, but NMCCA eliminated our ability to do that
by denying the motion without waiting for input from us.)
So it looks
like no filing today, with one or two filings tomorrow.
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
|