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
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
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
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
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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