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RE: 802 summary and trial dates U.S. v. Wacker
Gents,
Capt Day is at range classes this morning. We'll give you a call later today.
Maj Hatch
-----Original Message-----
From: Hur Capt Christian P
Sent: Friday, September 17, 2010 8:13 AM
To: Day Capt Evan S; 'haytham@puckettfaraj.com'
Cc: Hatch MAJ Douglas C
Subject: RE: 802 summary and trial dates U.S. v. Wacker
Capt Day,
I'd prefer not to go 19 to 21 November for family reasons myself. My Dad, who lives overseas, should be in town visiting me and that is also the main time that I spend time with my daughter. I'm generally available during the week days around that time period though.
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: Day Capt Evan S
Sent: Thursday, September 16, 2010 17:40
To: Jones LtCol David M; Sullivan LtCol Sean; 'haytham@puckettfaraj.com'
Cc: Rubin LtCol Peter R; Hur Capt Christian P; Hatch MAJ Douglas C
Subject: 802 summary and trial dates U.S. v. Wacker
Good Afternoon Gentlemen,
Here is a summary of our RCM 802 conference call this afternoon:
- Currently docketed motions/trial dates will be postponed.
- Art 39(a) session will be docketed at on 11 Oct 10 at 1600 at MCB Camp Pendleton (following US v Wuterich motions) IOT discuss witness production issues for UCI and other motions.
- Motions hearing will be 22-24 November, trial 31 Jan 10- 11 Feb 10.
- Counsel will re-submit charge sheet and allied papers (TC) and motions (all) to MJ.
- Counsel will negotiate new milestones and submit consent MFD with excludable delay.
I apologize for not raising the issue at the proper time, but I would respectfully ask to reconsider the 22-24 November motions date.
- From a practical standpoint, those dates will create conflicts with vacation plans for a large number of witnesses. Those conflicts will result either in witnesses needing to cancel travel plans or not be produced in person. Additionally, travel arrangements will be considerably more expensive and less flexible, particularly for last-minute changes.
- On a personal level, I have leave set for 19 Nov- 6 Dec, and have had leave set for a while. The purpose of leave is to drive up to Seattle with my wife and 3 kids to see my extended family. Holding the motions hearing on 22-24 November is going to effectively cancel my Thanksgiving plans since I am not going to be able to get a pre-school-age child and 7-month-old twins on a commercial flight on 24 or 25 November. If no other time is available, I would strongly prefer the weekend (19-21 November) as opposed to 22-24 November.
Again, I should have raised the issue when it was discussed and I apologize for not doing so. However, I would like to determine if there is any other possible time, including a weekend in December.
Very Respectfully,
Captain Evan S. Day
Trial Counsel, Military Justice Office
Joint Law Center
3rd MAW/ MCAS Miramar
Comm: 858-577-1887
DSN: 312-267-1887
Fax: 858-577-1734
Classification: UNCLASSIFIED//LIMDIS
This e-mail is FOR OFFICIAL USE ONLY and is exempt from mandatory disclosure under FOIA. DoD 5400.7R, "DoD Freedom of Information Act Program", DoD Directive 5230.9, "Clearance of DoD Information for Public Release", and DoD Instruction 5230.29, and "Security and Policy Review of DoD Information for Public Release".
ATTORNEY-CLIENT PRIVILEGED COMMUNICATION OR ATTORNEY WORK PRODUCT. The information contained in this message is privileged. It is intended only to be read by the individual or entity addressed or their designee. If the reader of this message is not the intended recipient, you are on notice that any distribution of this message, in any form, is prohibited. If you have received this message in error, please immediately notify the sender and delete or destroy any copy of this message.
-----Original Message-----
From: Jones LtCol David M
Sent: Thursday, September 16, 2010 15:30
To: Sullivan LtCol Sean; 'haytham@puckettfaraj.com'; Day Capt Evan S
Cc: Rubin LtCol Peter R; Hur Capt Christian P; Hatch MAJ Douglas C
Subject: Re: Trial dates and motions in U.S. v. Wacker
Gents,
What is the phone number I dial?
LtCol Jones
David M. Jones
Circuit Military Judge
Western Pacific Judicial Circuit
Navy-Marine Corps Trial Judiciary
----- Original Message -----
From: Sullivan LtCol Sean
To: Jones LtCol David M; 'haytham@puckettfaraj.com' <haytham@puckettfaraj.com>; Day Capt Evan S
Cc: Rubin LtCol Peter R; Hur Capt Christian P; Hatch MAJ Douglas C
Sent: Thu Sep 16 23:13:24 2010
Subject: RE: Trial dates and motions in U.S. v. Wacker
Your honor, gentleman
I will not be participating in this afternoon's conference call due to mandatory requirement I must attend as SJA here at MCRD. Major Hatch and Captain Day will represent government
VRS
LTCOL Sean M. Sullivan, USMCR
Staff Judge Advocate, MCRD
3700 Chosin Ave, Building 12
San Diego Ca 92140
(O) 619 524 4104 DSN 524 4104
(BB) 619 302 2145
-----Original Message-----
From: Jones LtCol David M
Sent: Thursday, September 16, 2010 1:45
To: 'haytham@puckettfaraj.com'; Day Capt Evan S
Cc: Rubin LtCol Peter R; Hur Capt Christian P; Sullivan LtCol Sean; Hatch MAJ Douglas C
Subject: Re: Trial dates and motions in U.S. v. Wacker
Great, 0730 my time on Friday.
R,
LtCol Jones
David M. Jones
Circuit Military Judge
Western Pacific Judicial Circuit
Navy-Marine Corps Trial Judiciary
----- Original Message -----
From: Haytham <haytham@puckettfaraj.com>
To: Day Capt Evan S
Cc: Jones LtCol David M; Rubin LtCol Peter R; Hur Capt Christian P; Sullivan LtCol Sean; Hatch MAJ Douglas C
Sent: Thu Sep 16 10:22:51 2010
Subject: Re: Trial dates and motions in U.S. v. Wacker
That works for me.
Haytham Faraj
760-521-7934
Sent from my iPhone
On Sep 15, 2010, at 5:42 PM, "Day Capt Evan S" <evan.s.day@usmc.mil> wrote:
> Good Afternoon Gentlemen,
>
> I suggest 2230Z on Thursday, 16 Sep 10, which is 1530 in San Diego and 0730 in Japan if I have my math right. I can set up the conference call.
>
> Very Respectfully,
> Captain Evan S. Day
> Trial Counsel, Military Justice Office
> Joint Law Center
> 3rd MAW/ MCAS Miramar
> Comm: 858-577-1887
> DSN: 312-267-1887
> Fax: 858-577-1734
>
> Classification: UNCLASSIFIED//LIMDIS
> This e-mail is FOR OFFICIAL USE ONLY and is exempt from mandatory disclosure under FOIA. DoD 5400.7R, "DoD Freedom of Information Act Program", DoD Directive 5230.9, "Clearance of DoD Information for Public Release", and DoD Instruction 5230.29, and "Security and Policy Review of DoD Information for Public Release".
> ATTORNEY-CLIENT PRIVILEGED COMMUNICATION OR ATTORNEY WORK PRODUCT. The information contained in this message is privileged. It is intended only to be read by the individual or entity addressed or their designee. If the reader of this message is not the intended recipient, you are on notice that any distribution of this message, in any form, is prohibited. If you have received this message in error, please immediately notify the sender and delete or destroy any copy of this message.
>
>
>
> -----Original Message-----
> From: Jones LtCol David M
> Sent: Wednesday, September 15, 2010 13:50
> To: 'haytham@puckettfaraj.com'; Rubin LtCol Peter R
> Cc: Hur Capt Christian P; Sullivan LtCol Sean; Day Capt Evan S
> Subject: Re: Trial dates and motions in U.S. v. Wacker
>
> Gents,
>
> I have verified that I continue to be detailed to this case, so yes, we need an 802 to discuss the way forward. I am just about to take off for Japan so let's talk on my Friday or my Saturday.
>
> R,
>
> LtCol Jones
> David M. Jones
> Circuit Military Judge
> Western Pacific Judicial Circuit
> Navy-Marine Corps Trial Judiciary
>
> ________________________________
>
> From: Haytham Faraj <haytham@puckettfaraj.com>
> To: Rubin LtCol Peter R
> Cc: Hur Capt Christian P; Sullivan LtCol Sean; Day Capt Evan S; Jones LtCol David M
> Sent: Wed Sep 15 23:19:46 2010
> Subject: Trial dates and motions in U.S. v. Wacker
>
>
>
> Your honor,
>
> I request an 802 for any time tomorrow, September 16, to discuss dates in the Wacker case. He Wacker trial has been dislodged by the Wuterich trial. I donât believe Wacker has been rescheduled. My first open date for a two week trial is in February of 2011. I would like to discuss setting a new trial date and perhaps adjusting the 39a dates.
>
>
>
> Vr,
>
>
>
> Haytham Faraj, Esq.
>
> PUCKETT & FARAJ, PC
>
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