Sir, Not to be rude or combative, but the position of the government is that we do not agree to moving the trial milestones, and this will require a ruling from the military judge. Very Respectfully, 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: Haytham [mailto:haytham@puckettfaraj.com] Sent: Wednesday, April 20, 2011 13:40 To: Combe Capt Peter C Cc: White Capt Bret A; Tilney Capt Marc R Subject: Re: Lopez: Motions Deadline Both Capt white and I are in hearings or trial all this week. We all know the judge will grant our request because we have a good faith basis for our request. It doesn't make any sense to have to do this by motion if can agree. Haytham Faraj Sent from my iPhone On Apr 20, 2011, at 10:22 AM, "Combe Capt Peter C" <peter.combe@usmc.mil> wrote: > 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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