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RE: Lopez: Motions Deadline



Bret,

I just heard from Capt Tilney.  He indicates that he is not inclined to agree to any movement of the motions due date.

He's out today, but his phone number is 610-551-4731.  He's got some things going on with his son today, so he may not be the most responsive.

S/F
Capt Peter C. Combe II
Trial Counsel
Office of the SJA, MCB Quantico
3250 Catlin Ave.
Quantico, VA 22134 

Comm: (703) 784-0590  DSN: 278
Fax: (703) 784-0035  DSN: 278


-----Original Message-----
From: White Capt Bret A 
Sent: Wednesday, April 20, 2011 13:17
To: Tilney Capt Marc R; Combe Capt Peter C
Cc: haytham@puckettfaraj.com
Subject: RE: Lopez: Motions Deadline

Capt Tilney,

LtCol Robinson called me to chat about this and another case.  I told him that Defense really just wants to move the motions deadline and want to be able to give trial counsel enough time to respond before the 39a on 5 May.  

He stated that whatever we agree to as to your response date is good with him (moving the 39a would be a different matter and is not what we want).  

So, we propose 28 April for the motions deadline and 4 May as the response deadline.  Therefore, responses would be due the day before the 39a.  

If you agree, please reply accordingly and I'll forward to the judge.   

Semper fidelis,


Bret A. White
Captain, U.S. Marine Corps
Defense Counsel

Office of the Staff Judge Advocate
Marine Corps Base               
3250 Catlin Avenue                            
Quantico, VA 22134                           

Main:    703.784.4615/4628
Direct:  703.784.0405
Fax:     703.784.0259





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