I will make all the notes IE61 - defense please focus me as you deem appropriate in your closing comments. -----Original Message----- From: Sullivan LtCol Sean Sent: Monday, April 19, 2010 14:22 To: Sayegh LtCol Michael E; Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S Cc: 'farajh@gmail.com' Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER Sir, The only objection I would have to that is without the total exhibit containing all pages, you cannot take the notes and all comments contained therein within context. Thus, I think best method is all notes come in as exhibit for record and then defense counsel in written argument due at end of week can argue those specific entries they feel are important for your consideration VRS LtCol Sean M. Sullivan, USMCR Senior Trial Counsel, MARCENT Legal Services Support Section 1st Marine Logistics Group Box 555067, Camp Pendleton, CA 92055-5607 Comm: (760) 763-9904/9902/9900 DSN: 361-9904 Fax: (760) 763-9901 Classification: UNCLASSIFIED//LIMDIS This e-mail is FOR OFFICIAL USE ONLY and is exempt from mandatory disclosure under FOIA. DoD 5400.7R, "DoD Freedom of Information Act Program", DoD Directive 5230.9, "Clearance of DoD Information for Public Release", and DoD Instruction 5230.29, and "Security and Policy Review of DoD Information for Public Release". ATTORNEY-CLIENT PRIVILEGED COMMUNICATION OR ATTORNEY WORK PRODUCT. The information contained in this message is privileged. It is intended only to be read by the individual or entity addressed or their designee. If the reader of this message is not the intended recipient, you are on notice that any distribution of this message, in any form, is prohibited. If you have received this message in error, please immediately notify the sender and delete or destroy any copy of this message. -----Original Message----- From: Sayegh LtCol Michael E Sent: Monday, April 19, 2010 2:16 PM 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 Lets do this then, I will not add an IE 61 at this time. If you find a discrepancies or other section you want to highlight for my consideration, literally do that and provide it to me for what I will add as IE61. For instance if you find something you want me to take note of on page 14 - pull that particular page, highlight it with a marker (or circle it) and make that the first page of IE61, and so on and so on. Does this make sense to everyone? -----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
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