Gentlemen, I am headed out on leave to the east coast. I can be reached at 843-368-7180 or mmmjd@ymail.com. R. 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: Sullivan, Dwight H CIV USAF AFLOA/JAJA [mailto:Dwight.Sullivan@pentagon.af.mil] Sent: Wednesday, June 08, 2011 9:35 AM To: Haytham Faraj; kirk.sripinyo@navy.mil; neal@puckettfaraj.com Cc: babu_kaza@hotmail.com; Marshall Maj Meridith L; dhsullivan@aol.com Subject: SitRep 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
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