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Re: Motions ICO U.S. v. Wuterich



Your Honor,
As the govt had already approved all necessary experts, the defense concurs.
V/r,

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

Sent from my iPhone

On Apr 27, 2010, at 4:17 AM, "Jones LtCol David M" <david.m.jones5@usmc.mil > wrote:

All,

I have received no motions from the defense by 26 April, which was the submission deadline. Therefore, I understand there to be no issues regarding experts, etc. that need to be decided early so as not to delay our trial schedule. Considering these two government motions do not appear to be time sensitive, I recommend that we forgo the motions session in May and plan to meet up 26-27 August to litigate these two government motions and any further non time sensitive motions the defense may file. I need to know immediately if either side objects to this and if so, why.

R,

LtCol David M. Jones
Circuit Military Judge
Western Pacific Judicial Circuit
Navy-Marine Corps Trial Judiciary
Office: 645-7287 / 2156
Fax: 645-2035
From the U.S.: 81-611-745-7287 / 2156
-----Original Message-----
From: Gannon Maj Nicholas L
Sent: Tuesday, April 27, 2010 7:55
To: Jones LtCol David M
Cc: Haytham Faraj; Neal Puckett; Sullivan LtCol Sean
Subject: Motions ICO U.S. v. Wuterich

Your Honor,

The Government will be submitting two motions to the Court today, 26 April 2010. One is to admit AE 58 (the 60 min outtakes) and the other is a request for a reconsideration of a previous ruling related to crime scene photographs and their admissibility.

For the second motion, I would like to send color photographs to the Court for your consideration. However, I have to send hard copies as we do not have a color scanning capability, and the black and white photos that are attached to our motion are not very high quality.

Thus Sir, I respectfully request the best address to send a hard copy of both motions. I intend to send the motions by way of FEDEX.

Very respectfully,
Major Gannon

Nick Gannon
Major, USMC
Officer-in-Charge,
Legal Team Echo
Legal Services Support Section
1st Marine Logistics Group, Box 555607
Camp Pendleton, CA 92055-5607
Desk: 760-725-4820
Blackberry: 760-208-7090
Fax: 760-725-4500
nicholas.gannon@usmc.mil