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FW: US v. Scarselli: outstanding discovery issues



Dave,

The August email below captured most of what we needed, basically:

-HQMCIG HQBN height and weight results for a 2009 inspection

-Maj Higgins transcripts/tapes taken in connection with interviews she conducted

-SJA's initial response back to Mr. Gill concerning his investigation.

-As discussed below, the PMO training records we received are still incomplete.

-We also asked for the transcripts of SSgt Baker and Mr. Gill from the 39as and Article 32 hearings (Brookins and Humberston 32s).

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.
  

-----Original Message-----
From: Hur Capt Christian P 
Sent: Monday, August 02, 2010 16:54
To: Wareham Capt Jason R; Gilinsky Capt David
Cc: 'Faraj, Haytham'; Rubin LtCol Peter R
Subject: US v. Scarselli: outstanding discovery issues

Trial Counsel,

There are several outstanding discovery items that we have requested in this case, but still do not have.

We have reviewed a large cardboard box fed-exed to my office that contained thousands of pages of Headquarters Battalion training records, the majority of which were not PMO related.  Missing, however was the most critical documents we had requested, the HQMC IG inspection results for the BCP, height and weight survey of Headquarters Battalion (PMO) personnel conducted on or about May 2009.  As you may recollect, the military judge ordered this material at the last motion's hearing we had.

We are also still missing some of the PFT, rifle, pistol training records of PMO from 2008 to 2009.  

We are also missing the rifle training exemption letter for PMO from 2007 to 2008.

The reason we are asking for this material is that it concerns charges Maj Scarselli is facing (ie allegedly not maintaining the height and weight or training standards of his PMO Marines).

We are also waiting for the Maj Higgins recordings and interview notes concerning her interviews of GySgt Montes and other witnesses in this case about the December 2008 PFT and Capt Beck's case.  

Finally, we also need the (written) transcripts and the audio files (in a media player format) for all of the motion hearings.  Thank you.


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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