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Re: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
I am TAD. If def does does not provide - I will upon my return.
LtCol Sayegh --------------------------
Sent from my BlackBerry Wireless Handheld
----- Original Message -----
From: Hatch MAJ Douglas C
To: Sayegh LtCol Michael E; Day Capt Evan S; 'sean.sullivan@cox.net' <sean.sullivan@cox.net>
Cc: Hur Capt Christian P; 'Haytham@puckettfaraj.com' <Haytham@puckettfaraj.com>
Sent: Mon Apr 26 17:28:28 2010
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
Sir,
Government counsel did not receive the defense comments. Request that the comments be forwarded to us, as otherwise they are ex parte communications.
V/R
Maj Hatch
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 26, 2010 17:12
To: Day Capt Evan S; Hatch MAJ Douglas C; 'sean.sullivan@cox.net'
Cc: Hur Capt Christian P; 'Haytham@puckettfaraj.com'
Subject: Re: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
Yes. Rec. Before yours.
LtCol Sayegh --------------------------
Sent from my BlackBerry Wireless Handheld
----- Original Message -----
From: Day Capt Evan S
To: Sayegh LtCol Michael E; Hatch MAJ Douglas C; 'sean.sullivan@cox.net' <sean.sullivan@cox.net>
Cc: Hur Capt Christian P; 'Haytham Faraj' <Haytham@puckettfaraj.com>
Sent: Mon Apr 26 14:16:06 2010
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
Gentlemen,
Was there a written argument submitted by the defense?
V/R,
Capt Day
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Friday, April 23, 2010 17:23
To: Hatch MAJ Douglas C; 'sean.sullivan@cox.net'
Cc: Hur Capt Christian P; 'Haytham Faraj'; Day Capt Evan S
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
received. thanks all.
-----Original Message-----
From: Hatch MAJ Douglas C
Sent: Friday, April 23, 2010 17:17
To: sean.sullivan@cox.net; Sayegh LtCol Michael E
Cc: Hur Capt Christian P; Haytham Faraj; Day Capt Evan S
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
Sir,
Attached are the government comments. My apologies for the late submission.
FedEx address is:
Joint Law Center
Building 2244 Elrod Ave
San Diego, CA 92145
V/R
Maj Hatch
-----Original Message-----
From: sean.sullivan@cox.net [mailto:sean.sullivan@cox.net]
Sent: Friday, April 23, 2010 17:07
To: Hatch MAJ Douglas C; Sayegh LtCol Michael E
Cc: Hur Capt Christian P; Haytham Faraj; Day Capt Evan S
Subject: Fw: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
Sir
Maj Hatch is scanning government argument as we speak and will email to you immediately
Sf. Ltcol Sullivan
Sent from my BlackBerryR smartphone with SprintSpeed
-----Original Message-----
From: "Sullivan LtCol Sean" <sean.sullivan@usmc.mil>
Date: Fri, 23 Apr 2010 16:40:09
To: <sean.sullivan@cox.net>
Subject: FW: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
It is 16:35 and I have yet to receive anything from either side. Nothing negative will come from not submitting comments or objections to the IO, but if not received within the hour, nothing beyond what was argued at the hearing will be considered.
LtCol Sayegh
-----Original Message-----
From: sean.sullivan@cox.net [mailto:sean.sullivan@cox.net]
Sent: Thursday, April 22, 2010 9:50
To: Sayegh LtCol Michael E; Day Capt Evan S; Hur Capt Christian P; Haytham Faraj
Subject: Re: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
Rgr sir
Vrs. Ltcol Sullivan
Sent from my BlackBerryR smartphone with SprintSpeed
-----Original Message-----
From: "Sullivan LtCol Sean" <sean.sullivan@usmc.mil>
Date: Thu, 22 Apr 2010 09:24:51
To: <sean.sullivan@cox.net>
Subject: FW: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER
Gents:
Just a reminder these are due to me COB tomorrow. Please note I will be TAD all of next week but I will take what you submit with me. My intent is to have my report done by COB 5 May - a week from this Wed. I will launch an electronic version of the report and mail the entire thing via fedex to Miramar Law Center. Just need their FedEx address.
thanks.
LtCol Sayegh
-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 14:07
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER
Sir,
We will add any analysis of those notes to our argument due on Friday Sir. There were no major discrepancies noted by the defense between the hand written notes and the summaries of interviews.
Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone: (619) 524-8713
Fax: (619) 524-6784
Address: Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego, CA 92140
This email may contain Attorney Work Product. Please delete if you received this message in error.
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 13:59
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER
Gentlemen:
This is a 161 pages. Is the defense submitting that I need to read this or do they summarize their points adequately in their summations of the ROIs previously submitted? Alternatively, does the Government object if the defense submits an alternate exhibit - (61) - where they summarize what they feel is important for me to consider from what they read in the notes?
If either side prefers I read this in its entirety - I will.
s/f
LtCol Sayegh
-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 13:38
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER
Sir,
I believe the attached contains most if not all of the notes.
Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone: (619) 524-8713
Fax: (619) 524-6784
Address: Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego, CA 92140
This email may contain Attorney Work Product. Please delete if you received this message in error.
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 13:36
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER
Can someone send those to me please?
-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 11:44
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER
Sir,
61 was the handwritten notes of the NCIS agent that the defense received via email from the trial counsel.
Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone: (619) 524-8713
Fax: (619) 524-6784
Address: Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego, CA 92140
This email may contain Attorney Work Product. Please delete if you received this message in error.
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 11:02
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean
Subject: IE NUMBER 61 ICO CAPTAIN WACKER
Gents:
In gathering the IEs, I could not find an IE 61. I have IE 60 as the email from Lovette Robinson and then pick up with the statements of Cook and Barker as 62 and 63 respectively. Please confirm that is an admin oversight as opposed to me not having something.
thanks.
s/f
LtCol Sayegh