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RE: Maj Rowe BOI



ALCON:

A few things for your consideration.  

First, I would definitely like you to re-interview some of the witnesses (at a minimum Potter, Ogletree, and Vinson).

Second, Ogletree underwent a recent investigation for credit card fraud and pending disciplinary action (possible dismissal).

Around the time of the ball incident, but prior to, I counseled Vinson for disrespect.  Burgess and Ramirez were witnesses.  Vinson at the time, was a temp employee.

I will visit the club staff to determine if the video still exist.  Additionally, I'm working the character witness list as well.

I will continue to work / refine my personal statement to the board.

If at all possible (given scheduling), I would like the board to go mid to latter part of the month (anytime after Feb 10th would be ideal).

I signed and provided the 9th MCD Adjutant the acknowledgement form (dated 30 Nov).  I would also like to review / edit the discovery document.  Will provide changes / updates by COB today.

* While it doesn't mean a thing, I have 7 months, 14 days from separation (July 15th 2001 counting terminal leave and PTAD) and exactly 11 months from a retirement date of 1 Nov 11.

Thanks again! 

-----Original Message-----
From: Hur Capt Christian P 
Sent: Wednesday, December 01, 2010 10:35
To: Haytham Faraj; Rowe Maj Carlos O
Cc: Grey Capt Nicholas R
Subject: RE: Maj Rowe BOI

Haytham,

Capt Grey and I already spoke with all the witnesses when we thought we were going to a 32.  They are solid.

Who do you want to do the next round of edits before we get the discovery request out?  

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: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Wednesday, December 01, 2010 5:26
To: Hur Capt Christian P; Rowe Maj Carlos O
Cc: Grey Capt Nicholas R
Subject: RE: Maj Rowe BOI

Gentlemen,
I have made some corrections, then turned on the track changes function.  I would like this to be a joint effort.  Lets remove the witnesses from this discovery request.  I would like to have a chance to speak to all the witnesses before we request them. I don't have to personally do it but one of us must.

I think the video idea is a very good one if it is still there.  Remember, however, the government has no more power than we do.  Maj Rowe should personally go to the establishment and see if they have the video.  I think I remember that he has a good relationship with them.  If there is a video, there is no better way to impeach then to surprise them with it after they testify.  

Maj Rowe.  We need from you a solid list of 6 officers that can testify about you past performance and your character.  They should be senior to you.

-----Original Message-----
From: Hur Capt Christian P [mailto:christian.hur@usmc.mil]
Sent: Tuesday, November 30, 2010 6:09 PM
To: Haytham Faraj; Rowe Maj Carlos O
Cc: Grey Capt Nicholas R
Subject: RE: Maj Rowe BOI

As discussed, please review for editing.  Also, don't forget that we have the assistance of Capt Grey, Esq. on this case too.

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: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, November 30, 2010 11:53
To: Rowe Maj Carlos O; Hur Capt Christian P
Subject: RE: Maj Rowe BOI

Reviewed it.  Thanks.

Go ahead sign and return.  I will draft a request to continue the Board until February because I will not be available before then.

Chris, please put together a witness request to the CA.  We need a 6-8 good
character witnesses.   We should also request percipient witnesses that can
challenge the events alleged.

Carlos,  I need you to get together every fitness report, letter of appreciation, certificate, award and anything else that is positive from your career.

I want you to start working on a statement for the board. The one you created for the General is a good starting point.  I also want to know if you know of anything negative in your accusers personal files.  I DO NOT WANT YOU to obtain anything or send out anyone to get anything.  I simply want to know if there's anything negative there.



-----Original Message-----
From: Rowe Maj Carlos O [mailto:carlos.rowe@usmc.mil]
Sent: Tuesday, November 30, 2010 2:31 PM
To: haytham@puckettfaraj.com; Hur Capt Christian P
Subject: FW: Maj Rowe BOI

FYI

-----Original Message-----
From: Grogan 1stLt Stephen J [mailto:Stephen.Grogan@marines.usmc.mil]
Sent: Tuesday, November 30, 2010 13:18
To: Rowe Maj Carlos O
Subject: FW: Maj Rowe BOI

Sir,

   You will find the page requiring your signature on Enclosure (2) of the document.  Please date the document as well.  Thank you for your assistance.
I will CC you on my submission to SJA.

Very Respectfully,

First Lieutenant Stephen J. Grogan
Adjutant
Ninth Marine Corps District
3805 E. 155th St., Bldg 710
Kansas City, MO 64147-1309
Phone:  (816) 843-3879
E-mail: stephen.grogan@marines.usmc.mil
Web: http://www.marines.mil/unit/mcrc/9mcd


-----Original Message-----
From: Keske Maj Zenon W [mailto:zenon.keske@usmc.mil]
Sent: Tuesday, November 30, 2010 1:56 PM
To: Grogan 1stLt Stephen J
Cc: Bonnot Col Matthew J; Sullivan LtCol Sean
Subject: Maj Rowe BOI

1stLt Grogan,
Good morning. The CG, MCDC, has directed Maj Rowe to show cause for retention in the Marine Corps. Attached is the notification letter from the Depot Commander. Included as enclosures are Maj Rowe's rights at BOI and an acknowledgment form for his signature. Please give the attachment to Maj Rowe and scan and email me a copy of the signed acknowledgement and mail the original. We'll coordinate the date and time of the board with his defense counsel. If there are any questions, let me know.
r/s
Maj Keske


Maj Zenon Keske
Deputy Staff Judge Advocate
MCRD, San Diego
DSN: 524-4103
Comm: (619) 524-4103
zenon.keske@usmc.mil
zenonkeske@yahoo.com
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