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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