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RE: US v Wacker- Govt witness list



We don't need to list those already on the Gov't witness list, do we?

Chris, you have the experts names.

-dsw

Douglas S. Wacker
Captain, USMC
Future Operations Officer
MWHS-3, 3D MAW
douglas.wacker@usmc.mil
Wk: 858-577-6730
DSN: 267-6730
Cell: 858-401-9392

"Don't tell people how to do things, tell them what to do and let them surprise you with their results." ~George S. Patton 


-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Monday, February 07, 2011 10:48
To: Wacker Capt Douglas S; Hur Capt Christian P
Cc: douglas.wacker@gmail.com
Subject: RE: US v Wacker- Govt witness list

Everyone needs to be on the list except rebuttal witnesses.

-----Original Message-----
From: Wacker Capt Douglas S [mailto:douglas.wacker@usmc.mil] 
Sent: Monday, February 07, 2011 1:43 PM
To: Hur Capt Christian P
Cc: haytham@puckettfaraj.com; douglas.wacker@gmail.com
Subject: RE: US v Wacker- Govt witness list

Rhett Buttle is the student who was on the Critical Issues Board. He may be
able to discuss what the Board deliberated. He was not named in the subpoena
to USD, but is on the witness list.

The character witnesses previously requested are (please double-check):

Out: MajGen James Kessler (doesn't remember me); LtCol William Pigott
(nothing good to say about me)

LtCol Robert McCarthy
Maj Kenneth Lee
Henry de Vere White
Kelly Lowry
Cory Christianson
Jodi McShan

I think the only others that I would add are:
Maj Serano (XO, MWHS-3)
Capt Jiemar Patacsil (we have known each other since 1998 (4th LAAD Bn,
USMCR); attended TBS together and I am his son's godfather. His wife may
also be a good witness (Jennie Patacsil)
Jenny Meeker (she was the TA in our Lawyering Skills class during 1L year;
she knows all of the law school students requested by the Gov't; I had a
one-time sexual relationship with her and we remain friends).
*Dalliana Wacker (wife)
*LaNita Wacker (mother)
*Tracie Rosado (sister)
*Ted Wacker (brother)

*Don't know if they need to be identified.

I think that is about it. The experts need to be identified. All of the
witnesses from New Orleans are included. I don't know who else is needed...
please let me know if I'm forgetting anything.

-dsw



Douglas S. Wacker
Captain, USMC
Future Operations Officer
MWHS-3, 3D MAW
douglas.wacker@usmc.mil
Wk: 858-577-6730
DSN: 267-6730
Cell: 858-401-9392

"Don't tell people how to do things, tell them what to do and let them
surprise you with their results." ~George S. Patton 


-----Original Message-----
From: Hur Capt Christian P 
Sent: Monday, February 07, 2011 10:15
To: Wacker Capt Douglas S; Wacker Capt Douglas S
Subject: FW: US v Wacker- Govt witness list

FYI.  Please respond back with Defense witnesses you want ASAP.  Be
exhaustive.  We can always choose to not call people later.

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

This email may contain Attorney Work Product.  Please delete if you received
this message in error.
  


-----Original Message-----
From: Day Capt Evan S
Sent: Friday, February 04, 2011 16:16
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'
Cc: Sullivan LtCol Sean
Subject: US v Wacker- Govt witness list

Gentlemen,

Witness lists are due to opposing counsel today, per the MJ ordered trial
schedule. Please find attached the government witness list. 

With regard to expert witnesses:
- I will assume that you are designating Dr. Jacobs as a witness (and
therefore no longer a confidential consultant) after today unless I hear
otherwise. Our clerks have already begun coordinating his travel
arrangements.
- Since Dr. Rudin is only (so far) approved for consulting, I will need a
follow-up request if you want to designate her as a witness and have the CA
approve funding for her travel and testimony. If you do send in a request,
it will go a lot faster if the request includes everything required by RCM
703(c)(2)(B)(i) and 703(d) up front (i.e. proffer of expected testimony).
Once I get a compliant request, I will do everything I can to move it
through quickly.

Very Respectfully,
Captain Evan S. Day
Judge Advocate
Joint Law Center
3D MAW/MCAS Miramar
P.O. Box 452013
San Diego, CA 92145-2013
Comm: (858) 577-1862
DSN: 267-1862
evan.s.day@usmc.mil

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