Re: First draft

[Neal Puckett <neal@puckettfaraj.com>]

Your conflict is imputed vice actual. If you are ordered to active duty thus leaving the firm the conflict evaporates since you never had ACR with Salinas. We mapped it all out. We're good. BTW, Dwight confirmed that we only have a Hutchins issue because we lost you. There is no Hutchins with Haytham. You took one for the team and it was the right COA. 

Neal A. Puckett
LtCol, USMC (Ret)
Puckett & Faraj, PC
703.706.9566

Sent from my iPhone

On Oct 28, 2010, at 16:24, Colby Vokey <cvokey@fhsulaw.com> wrote:

> I don't understand how the court can grant the relief requested, i.e. restoring me as counsel, when our new conflict would prohibit such remedy anyway.  I'm sure you have already thought of that but just wanted to point it out anyway.
> 
> Colby
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
> Sent: Thursday, October 28, 2010 8:18 AM
> To: 'Sripinyo, Kirk Major NAMARA, CODE 45'; 'Neal Puckett'; DHSULLIVAN@aol.com
> Cc: Colby Vokey
> Subject: RE: First draft
> 
> Kirk,
> I made some corrections and added facts that I know are part of the record but were completely ignored by the military judge.
> 
> Best,
> Haytham
> 
> -----Original Message-----
> From: Sripinyo, Kirk Major NAMARA, CODE 45 [mailto:kirk.sripinyo@navy.mil]
> Sent: Thursday, October 28, 2010 8:10 AM
> To: Haytham Faraj; Neal Puckett; DHSULLIVAN@aol.com
> Subject: RE: First draft
> 
> Sir-
> 
>  I'm editing the draft while Col Sullivan and Mr. Puckett are in the training.  Please send your edits and comments to me and I will incorporate.
> 
> v/r
> Major Kirk Sripinyo, USMC
> Appellate Defense Counsel
> Code 45, NAMARA
> kirk.sripinyo@navy.mil
> Commercial:  202-685-7093
> DSN: 325-7093
> Fax: 202-685-7426 
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Thursday, October 28, 2010 8:10
> To: 'Neal Puckett'; DHSULLIVAN@aol.com
> Cc: Sripinyo, Kirk Major NAMARA, CODE 45
> Subject: RE: First draft
> 
> I am working on the draft. 
> 
> 
> 
> Neal have you reviewed?  If not, I will send my draft to you rather than have two floating around.
> 
> 
> 
> From: Neal Puckett [mailto:neal@puckettfaraj.com]
> Sent: Thursday, October 28, 2010 6:58 AM
> To: DHSULLIVAN@aol.com
> Cc: haytham@puckettfaraj.com; kirk.sripinyo@navy.mil
> Subject: Re: First draft
> 
> 
> 
> Faraj RETIRED after 22 years of service vice resigning his commission. 
> 
> 
> Neal A. Puckett
> 
> LtCol, USMC (Ret)
> 
> Puckett & Faraj, PC
> 
> 703.706.9566
> 
> 
> 
> Sent from my iPhone
> 
> 
> On Oct 28, 2010, at 1:24, DHSULLIVAN@aol.com wrote:
> 
>    Gentlemen,
> 
>     
> 
>    Here's a first draft.  I'll make a couple of apologies.  I'm sending you a true first draft without having given it an edit for two reasons -- one, I want to get it out to you now; and two, I doubt I'd catch 1/4 of the errors at this hour.
> 
>     
> 
>    My second apology is that I'm sending it to you without doing one final thing I want to do:  read through Hutchins again and mine it for language to insert at relevant points.  We'll need to do that at some point before we file.  (Perhaps Maj Sip can do that during the day tomorrow or I can do it once we're done with the NITA training, which will probably be NLT 1530 tomorrow.)
> 
>     
> 
>    Semper Fi,
> 
>    DHS
> 
>    <WuterichNMCCA mandamus petition.doc>
>