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Re: Brito Motions
Gents,
Good morning. Please delete me from the cc line. I am trying to keep my inbox from overloading while in Bremerton. Thanks.
R/
LtCol Rubin
----- Original Message -----
From: Keane LtCol Stephen F
To: Hur Capt Christian P; 'Faraj, Haytham' <Haytham@puckettfaraj.com>; Torresala Capt John W
Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R
Sent: Mon Sep 27 08:35:20 2010
Subject: RE: Brito Motions
Capt Hur:
Also, one thing I was going to tell you in the 802 that you can work on now is that you need to file an amendment to your motion to compel, by COB today, clearly and specifically listing the witnesses you are requesting compelled and the justification (proffer of relevance and necessity). I am not going to sift through your discovery requests in an attempt to ascertain who you are requesting. If there is any discovery that you are requesting that is not clearly and specifically articulated in your motion, again I am not inclined to sift through discovery requests and responses to correlate them for you, you must specifically articulate the request in the motion addendum.
r/
LtCol Keane
-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, September 27, 2010 8:02
To: Keane LtCol Stephen F; 'Faraj, Haytham'; Torresala Capt John W
Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R
Subject: RE: Brito Motions
1530 PST with your permission Sir.
Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:Â (619) 524-8713
Fax:Â (619) 524-6784
Address:Â 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.
Â
-----Original Message-----
From: Keane LtCol Stephen F
Sent: Monday, September 27, 2010 7:54
To: Hur Capt Christian P; 'Faraj, Haytham'; Torresala Capt John W
Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R
Subject: RE: Brito Motions
What time did you arrive at for the 802 conference?
R/
LtCol Keane
-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, September 27, 2010 7:30
To: 'Faraj, Haytham'; Keane LtCol Stephen F; Torresala Capt John W
Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R
Subject: FW: Brito Motions
Gentlemen,
I wanted to be sure you received this email from Mr. Faraj.
-Capt Hur
-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Sunday, September 26, 2010 17:22
To: Rubin LtCol Peter R
Cc: Hur Capt Christian P; 'Mariam Chamesseddine'; Day Capt Evan S
Subject: Brito Motions
Your honor,
We are submitting two additional motions in the U.S. v. Brito. We acknowledge that they are late. Some of the facts in the motions did not develop until after the original motions submission date.
Vr,
Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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