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RE: Draft 5 and Appendix
Like I said, it ain't elegant. It's longer than I'd like and not as punchy, but I think it's more important to get it in fast than to have it read as well as we'd like.
I think by far the most important thing in it are the Effron quotation and, even more, the wonderful Ryan quotation. I hope those are enough to make the NMCCA judges realize that this isn't one to just gaff off.
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: Haytham [mailto:haytham@puckettfaraj.com]
Sent: Wednesday, May 25, 2011 3:21 PM
To: Sullivan, Dwight H CIV USAF AFLOA/JAJA
Cc: DHSULLIVAN@aol.com; neal@puckettfaraj.com; babu_kaza@hotmail.com; meridith.marshall@usmc.mil; kirk.sripinyo@navy.mil
Subject: Re: Draft 5 and Appendix
These dates are accurate. Well done on the petition.
Haytham Faraj
Sent from my iPhone
On May 25, 2011, at 1:04 PM, "Sullivan, Dwight H CIV USAF AFLOA/JAJA"<Dwight.Sullivan@pentagon.af.mil> wrote:
> Here's the part we want to verify. I based the dates on e-mails that told me when things were expected to happen, so I'm not sure that that's when they actually did happen:
>
>
> 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
>
>
>