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Re: Off to Oki



The more time the merrier. You can't imagine how much fun it would be to make Judge Jones give us more time if it came to that!  Please ensure brief is not filed BEFORE the deadline. More pain and suffering for TC is better. 

Neal A. Puckett
LtCol, USMC (Ret)
Puckett & Faraj, PC
703.706.9566

Sent from my iPhone

On Feb 6, 2011, at 15:31, DHSULLIVAN@aol.com wrote:

Under CAAF's latest order, it's now due 24 Feb.  But I'm leaving for African on 14 Feb, so I'd like to have it ready to file NLT 15 Feb.  We can do a  bit of consideration as to when it's in our optimal interest to file.  The government has 10 days to file an answer (though I bet they do it more quickly), then we have 5 days to file a response.  Because I won't be back from Africa until 3 March and I will be completely unreachable while I'm there, I'd prefer we file closer to 24 Feb than to 15 Feb. 
 
Neal, is there any reason from a trial defense standpoint to file it closer to the 14th?
 
CAAF's latest order, with the new filing deadlines, is attached.
 
Semper Fi,
DHS
 
In a message dated 2/6/2011 3:26:45 P.M. Eastern Standard Time, neal@puckettfaraj.com writes:
Used to be 31 Jan and we got 10 day extension. Is my math wrong?

Neal A. Puckett
LtCol, USMC (Ret)
Puckett & Faraj, PC
703.706.9566

Sent from my iPhone

On Feb 6, 2011, at 15:23, DHSULLIVAN@aol.com wrote:

Neal,
 
Let me review the order, but my understanding is that our deadline is no longer 10 Feb, but is sometime in mid-Feb.  Let me check and get back to you.
 
Semper Fi,
DHS
 
In a message dated 2/6/2011 2:36:24 P.M. Eastern Standard Time, neal@puckettfaraj.com writes:
Folks,
Leaving this afternoon for Okinawa.  At Reagan airport now.  Will try to ensure regular email contact, but phone calls will be rough.  Will review ASAP the brief when it's circulated, but by no means wait on my review/approval if we're up against the 10 Feb deadline.  I'm really excited to see what the braintrust produces!
S/f,
Neal
Neal A. Puckett, Esq
LtCol, USMC (Ret)
Puckett & Faraj, PC
1800 Diagonal Rd, Suite 210
Alexandria, VA 22314
703.706.9566

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