OK, roger that. As for the discovery request, two quick things. 1. I'm going to send out the generic initial discovery request, but I made a specific request for the audio recording of the pretext phone calls. I know Capt Hoover is working on that anyway, but I figured I would not wait until we send out a more detailed discovery request to ask for it. 2. Do you want me to include requests for past investigations (w/ audio/video) into Lt Klay's previous misconduct? Specifically her charges and investigation related to hitting the Cpl in the street? There is a video of Lt Klay slapping a Cpl. She mentions that incident in her statements and I believe the confrontation was related to the issue with Rowe and possibly some others. As for the witness request, so far I have only: Capt Ben Klay, Cpl Quinn, NCIS Agent Janise A. Buckmon. Do we want to ensure "Jeremy" (last name escapes me) is there or can testify telephonically? s/f Matt -----Original Message----- From: Haytham [mailto:haytham@puckettfaraj.com] Sent: Monday, May 23, 2011 15:41 To: Mcconnell Maj Matthew N Cc: Rowe Capt James M Subject: Re: Article 32 prep I already coordinated with Nute Bonner to have Quinn available. Haytham Faraj Sent from my iPhone On May 23, 2011, at 6:21 AM, "Mcconnell Maj Matthew N" <matthew.n.mcconnell@usmc.mil> wrote: > Haytham, > > Roger to all. Will be at your office at 0900 on the morning of the 2nd. Taking Metro from there is fine. I'm going to bring our clerk, LCpl Ortega (bearing a camera), IOT have a foundational witness present. > > s/f > Matt > > -----Original Message----- > From: Haytham [mailto:haytham@puckettfaraj.com] > Sent: Saturday, May 21, 2011 8:59 > To: Rowe Capt James M > Cc: Mcconnell Maj Matthew N > Subject: Article 32 prep > > Jim, > I need you to coordinate travel plans so that you can meet me and Maj McConnell in Washington DC on June 2nd. Your command should pay for it. If they ask why you need to go early, explain that your lawyers want to do pre hearing prep with you. Be prepared to meet at 8th and I at 1100 on June 2nd. I want to see where Klay lived, see inside the house, measure the distance to the bar that she was at, and interview several witnesses. > > Matt, Parking will probably be an issue. We can rally at my office in Alexandria and metro to the Barracks. Let me know if that works for you. > > s/f > > Haytham Faraj > Sent from my iPhone
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