Re: Bell Motion

On Jan 31, 2011, at 11:40 AM, Marshall Maj Meridith L wrote:

Gentlemen,

Doug - I am the one who mentioned bringing Mr. James Bell (Dad) out.

R/

Major Meridith L. Marshall
Senior Defense Counsel
MCAS, Miramar
858-577-1720
meridith.marshall@usmc.mil

-----Original Message-----
From: Hatch MAJ Douglas C
Sent: Monday, January 31, 2011 8:38 AM
To: Puckett Neal
Cc: Marshall Maj Meridith L; Faraj Haytham
Subject: RE: Bell Motion

Neal,

This may sound strange, but I don't think I'll be able to get less than 27 years. I am seriously not nickel and diming you here--everyone is concerned about the relative ages of Makeisha and GySgt Bell upon his release, and I've done the calculations based on standard good time credit. A 27 year sentence seems to be the magic number (at the low end). If you can get me something in writing, plus a stip, I think I can sell 27 to the CA.

I know the charge re: viewing porn was a sticking point. Is he willing to plead guilty to everything else? For example, the sodomies were pled in the alternative--he'd have to plead to the sodomy under 125, not to the 120's pled in the alternative.

I also have some very specific evidentiary concessions I'll want in there, and I much to prefer to work that out ahead of time rather than amending the PTA later. I wouldn't ask you to stipulate to admissibility, but there will be several pieces of evidence (affidavits, possibly videos) I'd want to get in without having to lay a foundation; Confrontation would need to be waived is some instances of course. We can always duke out relevance.

Either you or Meridith mentioned bringing GySgt Bell's dad out here, and that won't be a problem.

What do you think?

Doug

-----Original Message-----
From: Puckett Neal [mailto:neal@puckettfaraj.com]
Sent: Monday, January 31, 2011 7:49 AM
To: Hatch MAJ Douglas C
Cc: Marshall Maj Meridith L; Faraj Haytham
Subject: Fwd: Bell Motion

Doug,
Here ya go. Thanks for making it easy.
Now, if you could just get me a 26-yr deal, we could be done with this case without any pain or suffering.
Neal

Neal A. Puckett, Esq
LtCol, USMC (Ret)
Puckett & Faraj, PC
1800 Diagonal Rd, Suite 210
Alexandria, VA 22314
703.706.9566
www.puckettfaraj.com

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Begin forwarded message:

From: "Bethany Trujillo" <bethany@puckettfaraj.com>

Date: January 31, 2011 10:45:11 AM EST

To: "Neal Puckett" <neal@puckettfaraj.com>

Subject: Bell Motion

Neal,
Attached.

Bethany N. Trujillo
Office Manager/Legal Secretary

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