Today Sir. Mr. Faraj has given me the UCI motion and I'm doing the final proof read for errors. 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: Rubin LtCol Peter R Sent: Monday, November 01, 2010 8:36 To: Hur Capt Christian P; 'Faraj, Haytham'; Gilinsky Capt David; Wareham Capt Jason R Cc: Grisalesmery Cpl Alejandro Subject: RE: US v. Scarselli: Defense motion for reconsideration, Part I I received the emails/attachments. I would like to litigate all remaining matters well in advance of trial. When will the UCI motion be filed? The Govt must be given time to respond. R/ LtCol Rubin -----Original Message----- From: Hur Capt Christian P Sent: Monday, November 01, 2010 8:19 AM To: Rubin LtCol Peter R; Grisalesmery Cpl Alejandro Cc: Gilinsky Capt David; Wareham Capt Jason R; 'Faraj, Haytham' Subject: US v. Scarselli: Defense motion for reconsideration, Part I Sir, Attached is the defense motion for reconsideration of your previous suppression ruling regarding the 8 July 2009 interview based on new evidence not previously considered by yourself when deciding this issue (namely the Mr. Gardner sworn statement and the LtCol McGowan and Maj Blair reports given to Mr. Gill pre-July 2009). Mr. Faraj told me that he is very soon going to file an additional motion seeking to dismiss the case on the basis of unresolved UCI. Mr. Faraj also told me (assuming charges are not dismissed because of UCI) that he wants this case to go trial as planned on 30 November so as to not burden the court because of continuances occurring in several cases right now. The defense proposes that we litigate this motion and the UCI motion that Mr. Faraj will be filing before trial on the merits begins on 30 November so as to not disrupt the calendared trial dates. 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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