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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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