We need to be as in depth as possible. We should also ask the court to compel production of documents in that regard. 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: Wacker Capt Douglas S Sent: Monday, January 24, 2011 9:09 To: Hur Capt Christian P Cc: 'douglas.wacker@gmail.com'; haytham@puckettfaraj.com Subject: RE: homework: exparte motion to produce UCI motion witnesses Chris, I will put together a list of the individuals for the UCI/Wrongful Withdrawal witness list. How in depth does the justification need to be? Should we also request the Court to compel discovery on the documents we recently requested involving the Government's investigation of the UCI at MCRD? S/F Doug 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: Friday, January 21, 2011 15:15 To: douglas.wacker@gmail.com; Wacker Capt Douglas S Subject: homework: exparte motion to produce UCI motion witnesses Doug, Haytham and I discussed today that the road ahead in your case is to first file an exparte motion with the judge requesting the witnesses for the UCI/wrongful withdrawal motions. In the motion, we will list every witness we want and what they will say and why we want them. I've attached a draft witness request motion. Can you do the first cut on this? You will need to work first because the earliest I can start on it is the week after next and time is of the essence. Thanks. 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.
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