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Re: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Rgr sir

Vrs. Ltcol Sullivan
Sent from my BlackBerry® 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