RE: Have You Heard Questions

["Hur Capt Christian P" <christian.hur@usmc.mil>]

This is a multi-part message in MIME format.

Sir,

Are you saying you already approved these areas or are these areas you expect to be litigated?  

Thank you.

Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 12, 1st Floor, MCRD, San Diego, CA 92140

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-----Original Message-----
From: Jones LtCol David M 
Sent: Friday, March 04, 2011 17:15
To: Day Capt Evan S
Cc: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Sullivan LtCol Sean
Subject: Have You Heard Questions

Gents,

In anticipation of the defense starting their case, I want to ensure that I am aware of ALL of the potential "Have you Heard" or "Did You Know" questions the government may plan on asking if the defense puts on good character evidence.  This method allows the defense to plan accordingly and alerts the Court and the defense so we don't have any surprises necessitating Article 39(a) sessions.

Here is what I have as potential areas that may form the basis of "Have you Heard" type questions.  

--That the accused was called "Creepy Doug."
--That the accused used adderall.
--That the accused drugged a former girlfriend.

If there are any issues regarding any of these areas, we will need to litigate them.  

I need to know if there are any OTHER questions I have missed.  I don't wish to be surprised and the defense should have fair notice also.

R, 

LtCol David M. Jones
Military Judge
Western Pacific Judicial Circuit
Navy-Marine Corps Trial Judiciary
Office: 645-7287 / 2156
Fax: 645-2035