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Is that a FOIA request or is such a
request made in another way? From: Wolford Lisa
[mailto:lisa@csss.net] You can request his records from National
Personnel Records in Lisa N. Wolford CSSS.NET 402-393-8059w 402-393-1825f SDVOB, 8(a)/SDB & WOB - TS clearances From: Kevin
Duff [mailto:kduff@rddlaw.net] We requested that he produce his military
records. He said he does not have any. From: Wolford Lisa
[mailto:lisa@csss.net] Kevin - Didn't we get a copy of Cyanowa's DD214? Lisa N. Wolford CSSS.NET 402-393-8059w 402-393-1825f SDVOB, 8(a)/SDB & WOB - TS clearances From: Haytham
Faraj [mailto:haytham@puckettfaraj.com] Kevin, This is very well
written. It’s comprehensive in its coverage of the issues. Well
done! I only have a couple of comments. at page 12 2nd
Paragraph under E, you say “it is beyond cavil.” Not sure
what cavil means. Also, is it possible to get an affidavit from Noel
Flanagan regarding the statement to Bill Slater. The reason I wanted
to take a look at Cynowa’s military record and DD-214 is because of
statements he made in his deposition that raised serious doubts in my mind
about his service. 1) The term MOS is burned into the memory of
service members. It stands for military occupational specialty. He
said it stands for “method of service” Depo. P. 37, line 20.
The reason people know and remember that term is because you spend the first
few weeks and sometimes months of your military life competing to get the MOS
you desire. And you spend the rest of your military career working to
remain competitive and relevant in your MOS. There is no way someone
would forget what that stands for. Also the entire exchange at the truck
with officer Androwski is odd. Most Marines who come across another
Marine would engage in conversation about a) the MOS they had; b) the
units they served in; c) the locations and dates they served. Of course
he did not serve in the Marine Corps –he served in the Army- yet he has a
Marine Corps sticker on his truck. 2) He says he may have fired an AK-47
in boot camp. Boot camp is not a memory that is easily forgotten even
with the passage of time. Neither the Army nor the Marine Corps fire
soviet (in 1985) weapons in their basic training. I went to boot camp in
1986. I, as well as my friends from boot camp, have specific memories and
details from boot camp. I remember the day when I first fired a weapon
and my time on the rifle ranges. Mr. Cynowa says he did not compete
Marine Corps boot camp. I have some doubts about whether Mr. Cynowa
completed any full term of service in the military at all. From: Kevin Duff
[mailto:kduff@rddlaw.net] Lisa, Bill, and Haytham, Attached are: (i) the summary judgment
brief along with (ii) an affidavit for Bill Slater. Please let me know
any comments you have as soon as possible. Ideally, I would like to file
the motion tomorrow. Please note that we are subject to a
15-page limit on the brief. Kevin Kevin B. Duff Rachlis Durham Duff & Adler, LLC phone: 312-733-3390 fax: 312-733-3952 mobile: 312-218-8620 RACHLIS This transmission may be: (1) subject to
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