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RE: affidavit



No Sir.  Have a safe deployment.  Haytham is providing advice on Hawk's appeal.  He's also working on Wacker so at some point we may need you to testify on that case.

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: Bueno Maj Robert M [mailto:robert.bueno@marcent.usmc.mil] 
Sent: Wednesday, October 27, 2010 2:34
To: Hur Capt Christian P
Subject: RE: affidavit

Capt Hur,

I saw I missed your call.  Still need to talk?  This is my new e-mail.  Let me know if you still need something from me.

Thanks and Semper Fi,
Maj Bueno

-----Original Message-----
From: Hur Capt Christian P [mailto:christian.hur@usmc.mil] 
Sent: Wednesday, October 20, 2010 5:35 PM
To: Bueno Maj Robert M; Bueno Maj Robert M
Cc: Mcdonald Capt Michael J
Subject: RE: affidavit

Thank you Sir for your courage and integrity.  

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: Bueno Maj Robert M 
Sent: Wednesday, October 20, 2010 0:14
To: Hur Capt Christian P; Bueno Maj Robert M
Cc: Mcdonald Capt Michael J
Subject: RE: affidavit

Capt Hur,

I apologize for not getting this to you today.  As I stated, I was at an Art 32 hearing and am getting ready to deploy (I am finishing up some things before I report to Pendleton tomorrow).  Please find the enclosed statement.  I will sign and have my Marine scan and forward to you and Mike first thing tomorrow morning.  I should talk to LtCol Tafoya about other things for him to do as he sees fit.   

Thanks and Semper Fi,
Maj Bueno

-----Original Message-----
From: Hur Capt Christian P 
Sent: Monday, October 18, 2010 14:33
To: Bueno Maj Robert M; Bueno Maj Robert M
Cc: Mcdonald Capt Michael J
Subject: affidavit

Sir,

I just spoke with you and want to make sure that everything I typed is correct. As you know, I'm working on a 69b appeal for SSgt Hawk.  Below are my notes from the interview that I will use for the appeal.  Will you please confirm if this is correct or incorrect based on your recollection?  Please make any additions or changes.  I've attached an affidavit template for your convenience if you don't want to respond back via email.  Thank you Sir.

///////////////////


During a meeting with Col Smith, Agent Rendon was present in the conference room.  Another agent was present too.  She told me (referring to Daniel Ligon) "have you interviewed her?"  I said that yes I had and that her intent was just to meet with a friend and to just hang out, it wasn't to hook up.

Col Smith then said "Rob that's not going to make her believable.  She needs to say that she went there knowing that there was somebody waiting for her to hook up and that her intent was to meet this Hawk guy before showing up.  Because you can't paint her to be the virgin mary (Col Smith may have said Mother Theresa).  You need to have her say that she went there knowing that she was going to be fixed up with another guy."

I looked at Agent Rendon and made I contact with him.  She was telling to change a witnesses testimony.  I believed that Col Smith, as the SJA, was directing him to change the victim Daniel Ligon's testimony in this case.

Later, the same female victim in the case, Daniele Ligon, told me that she didn't want to testify anymore and that she didn't want to be involved in the case at all.  Col Smith told me to get her back on board.  Col Smith said words to the effect, I don't care what you have to do.  Do whatever you have to do.

I kept at it until Daniel Ligon changed her mind and wanted to cooperate again.  

Regarding all of the other charges not related to Daniel Ligon, Col Smith was looking into Hawk's background herself, looking at his security clearance issues and drunk and disorderly conduct as the SJA on his case.  She brought all of that stuff up and handed it to me to prosecute.

Col Smith also found out that a CID agent was covering for Hawk.  Col Smith got a MSgt at CID relieved.

Col Smith dug up the petty cab and drunk and disorderly incidents against Hawk as the SJA.

I'm aware that in other cases Col Smith would frequently talk to witnesses.  

Many times Col Smith would say that defense witnesses should not want to testify for the defense...Col Smith did this in other cases.  I'm unaware if she did this in Hawk's case.

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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