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RE: Affidavit edit



Gentlemen, I am in receipt of the email and attachment.  I will review tonight and send back to both with any additional comments and a scanned copy of the charge sheet (as long as you do not mind that it is marred with my marginalia) ... NLT Thu.  Thanks for the hard work with this.  S/F!  R/The GF

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Monday, April 26, 2010 2:40
To: Christian Hur
Cc: Scarselli Maj Pietro P; Haytham Faraj
Subject: Re: Affidavit edit

I am in trial this week. I will review the attached by wednesday.

Haytham Faraj
760-521-7934
Sent from my iPhone

On Apr 25, 2010, at 8:57 PM, Christian Hur <christian.hur@gmail.com>
wrote:

> Gentlemen,
>
> I'm going to be out of the office all next week (I won't have access 
> to my NMCI computer files until the afternoon of 3 May).  I'll receive 
> gmails via my smartphone however.
>
> I know that Haytham had wanted me to create a supplemental UCI motion 
> fact section based on our last site visit.  I also know that Maj 
> Scarselli had asked me to do a draft of the motion to dismiss for 
> failure of the Government to have evidence to support its charges.
>
> To meet these two end-states, I've attached an early draft of this 
> motion (that also contains the UCI fact supplements).  In this motion, 
> I attempt to attack the Government's charges that we know they no 
> longer have any evidence to support:  false official statement charges 
> based on excluded statements, the GySgt Buchanan charges, etc.
>
> I propose (if acceptable with you two) that Maj Scarselli first edit 
> the attached draft with facts and then send it back to me along with a 
> scanned copy of the charge sheet (if he has it).  I don't have the 
> charge sheet on my home computer, which is why the attached needs much 
> editing.  I'll then finish up the edits once I get Maj Scarselli's 
> version back and then send to Haytham for finalization and filing.
> Please let me know if either of you want to do something else.  I'm 
> tracking for 17 May as the date of the 2nd Motion's hearing (which 
> means we probably need to file the attached NLT first week of May).
>
> Thanks.
>
> On Fri, Mar 26, 2010 at 12:30 PM, Scarselli Maj Pietro P 
> <pietro.scarselli@usmc.mil> wrote:
>> Christian, please review soonest and let me know of any further  
>> changes, if any...or if I should print, sign, scan and email back.   
>> Please note significant changes.
>>
>>
>>  Standing by....
>>
>>
>> Thanks.  S/F!  R/Maj Scarselli
>>
>> This email may contain Attorney Work Product.  Please delete if you 
>> received this message in error.
>>
>
>
>
> --
> Christian P. Hur
> <Scarselli Motion to dismiss failure of evidence.doc>

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