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RE: Draft 5 and Appendix



Here's the part we're not sure of. (I based the dates on when things were expected to happen; if plans changed -- as they often do -- some of these dates are probably wrong.)


Following the Court of Appeals for the Armed Forces' ruling on his writ appeal, on 15 April 2011, Petitioner filed a Motion to Abate Proceedings Pending Involuntary Recall of Mr. Vokey to Active Duty.  The Government filed a written opposition on 22 April 2011.

Respondent Judge Jones held an Article 39(a) session to receive evidence and hear argument on the motion on 25-26 April 2011.  Following the hearing, on 29 April 2011, the Government submitted additional evidence, including two affidavits of individuals Petitioner had no ability to cross-examine.


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  


-----Original Message-----
From: Haytham [mailto:haytham@puckettfaraj.com] 
Sent: Wednesday, May 25, 2011 3:07 PM
To: Sullivan, Dwight H CIV USAF AFLOA/JAJA
Subject: Re: Draft 5 and Appendix

I can't see highlights on my phone. What are the dates that we want to check?

Haytham Faraj 
Sent from my iPhone

On May 25, 2011, at 11:25 AM, "Sullivan, Dwight H CIV USAF AFLOA/JAJA"<Dwight.Sullivan@pentagon.af.mil> wrote:

> Here's Draft 5, with some minor changes, and the Appendix.
> 
> We're still waiting to hear from Haytham and/or Maj Marshall about the
> highlighted dates.
> 
> Maj Sip, do I need to do an index and table of authorities?
> 
> I think we're close -- we should be able to wrap this up very soon after Maj
> Sip finishes his moot.
> 
> 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  
> 
> 
> -----Original Message-----
> From: DHSULLIVAN@aol.com [mailto:DHSULLIVAN@aol.com] 
> Sent: Wednesday, May 25, 2011 1:05 AM
> To: neal@puckettfaraj.com; Sullivan, Dwight H CIV USAF AFLOA/JAJA
> Cc: babu_kaza@hotmail.com; haytham@puckettfaraj.com;
> meridith.marshall@usmc.mil; kirk.sripinyo@navy.mil
> Subject: Re: Wuterich update
> 
> I'm way past the point of diminishing returns for the night, so I'm going to
> pack it in and finish this tomorrow.
> 
> I'm attaching a very, very rough draft of the first 21 pages (ignore
> anything past page 21).  Please don't feel a need to review this working
> draft, but also feel free to do so and provide revisions if you wish.  But
> I'll be circulating another draft on Wednesday.
> 
> Semper Fi,
> DHS
> <Wuterich_Petition for Stay (25 May 2011) Draft 5.doc>
> <Wuterich appendix.docx>