Chris, Here is an edited version from my brother. S/F Doug -----Original Message----- From: Ted Wacker [mailto:Twacker@rcrlaw.net] Sent: Thursday, April 22, 2010 12:14 To: Wacker Capt Douglas S Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER Doug, I am getting ready for a huge deposition in the moring... However, I have reviewed and made some changes and comments for you and your attornes to consider if you wish. Ted -----Original Message----- From: Wacker Capt Douglas S [mailto:douglas.wacker@usmc.mil] Sent: Thursday, April 22, 2010 10:40 AM To: Ted Wacker Subject: FW: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER Ted, Here are the two documents. Let me know what you think. -Doug -----Original Message----- From: Wacker Capt Douglas S Sent: Thursday, April 22, 2010 10:08 To: Hur Capt Christian P Cc: 'haytham@puckettfaraj.com'; 'douglas.wacker@gmail.com' Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER It's not in the same format, but it uses some of the information you cover and adds/changes some. It was too complicated to just make changes/comments. Either of you may feel free to reformat/add/delete/change, etc. Make sure that your copy at the very least states in paragraph (a) that '"no" evidence' exists of any drugs, you forgot the "no". -dsw -----Original Message----- From: Hur Capt Christian P Sent: Thursday, April 22, 2010 9:27 To: Wacker Capt Douglas S; 'douglas.wacker@gmail.com' Subject: FW: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER Doug, Are you going to give me an edited version of what I sent you yesterday? Thanks. 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: Thursday, April 22, 2010 9:25 To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S; Sullivan LtCol Sean; 'farajh@gmail.com' Subject: 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
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