Haytham,
Attached is something that I've used in 120 cases before. LtCol Jones like it b/c it kept the 'prying questions' down to a minimum during voir dire, but still got us the necessary info.
Whatchathink?
S/F
~Russ
-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Friday, November 18, 2011 16:54
To: Shinn Capt Scott R
Subject: Re: US v. Rowe - Photographic evidence
This all from March of this year. Nothing helpful here.
Haytham Faraj
Sent from my iPhone
On Nov 18, 2011, at 4:43 PM, "Shinn Capt Scott R" <scott.shinn@usmc.mil> wrote:
> Haytham,
> I didn't get it. Can you resend?
>
> Text images are attached. I presume they are texts from Klay, but unknown who they are to. Additionally, they don't have the other person's responses.
>
> ~Russ
>
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Friday, November 18, 2011 16:27
> To: Shinn Capt Scott R
> Subject: Re: US v. Rowe - Photographic evidence
>
> I emailed it earlier today. Tell me about the texts.
>
> Haytham Faraj
> Sent from my iPhone
>
> On Nov 18, 2011, at 3:30 PM, "Shinn Capt Scott R" <scott.shinn@usmc.mil> wrote:
>
>> Haytham,
>> I went down to Maj McConnell's office after we talked and looked through his case file again. There were some additional things that I didn't have - photos of some text messages and Buckmon's notes.
>>
>> What's the story on these text messages?
>>
>> Also, can you forward me LtCol Bracknell's Art 32 report?
>>
>> Thanks!
>>
>> ~Russ
>>
>> -----Original Message-----
>> From: Mcconnell Major Matthew N
>> Sent: Friday, November 18, 2011 10:53
>> To: Shinn Capt Scott R
>> Subject: FW: US v. Rowe - Photographic evidence
>>
>>
>>
>> -----Original Message-----
>> From: Hoover Capt Christopher M
>> Sent: Thursday, June 09, 2011 7:20
>> To: Robert Bracknell
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N; Hoover Capt Christopher M
>> Subject: US v. Rowe - Photographic evidence
>>
>> Gentlemen,
>> These are the five photos of the text messages.
>> Respectfully,
>>
>> Captain Christopher M. Hoover, USMC
>> Military Justice Officer MCB Quantico
>> Work: (703) 784-0037
>> Cell: (603) 809-5781
>>
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Friday, June 03, 2011 17:20
>> To: Hoover Capt Christopher M
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>>
>> mcdsus.mcds.usmc.mil>
>> <>,<>
>> <>,<>
>> <>,<>
>> In-Reply-To: <>
>> Accept-Language: en-US
>> Content-Language: en-US
>> X-MS-Has-Attach:
>> X-MS-TNEF-Correlator:
>> acceptlanguage: en-US
>> Content-Type: text/plain; charset="us-ascii"
>> Content-Transfer-Encoding: quoted-printable
>> MIME-Version: 1.0
>> X-STM-SMTP: 2011-06-03 16:22:13;str=0001.0A020201.4DE95083.0105,
>> ss=1,fgs=0;Unknown
>> X-Mailshell-score: 1
>>
>> Well, it's training -- anything can be made up if you talk to the right per=
>> son -- like the AIT battalion commander. It's not like Captain Klay is tra=
>> ining to fly the space shuttle. But it's getting too late on Friday to coo=
>> rdinate particularly when we have an acceptable alternative -- the teleconf=
>> erence on Tuesday. Please provide the details for the phone conference on =
>> Monday, as you suggested.
>>
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Hoover Capt Christopher M [christopher.hoover@usmc.mil]
>> Sent: Friday, June 03, 2011 3:04 PM
>> To: Robert Bracknell
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>> Capt Klay has not been available today. I am told that I will not be abl=
>> e to reach him until 1900 tonight, our time. I was told that he is a stude=
>> nt at the light -armored vehicle course and the live fire exercise is not a=
>> n event that he can be readily pulled from. I am still working to get the =
>> information sought, but I think at this point it will be moot since he is u=
>> nlikely to be able to pull from the live fire exercise and I will not get t=
>> he information sought until this evening. Please let me know if you still =
>> need chain of command contact info.
>>
>> I am working on the teleconference piece also. I don't have the number or =
>> instructions yet, but I will have that for Monday at the Art 32.
>>
>> Captain Christopher M. Hoover, USMC
>> Military Justice Officer MCB Quantico
>> Work: (703) 784-0037
>> Cell: (603) 809-5781
>>
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Friday, June 03, 2011 13:51
>> To: Mcconnell Maj Matthew N
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Capt Hoover, what's the story on Capt Klay?
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Mcconnell Maj Matthew N [matthew.n.mcconnell@usmc.mil]
>> Sent: Friday, June 03, 2011 1:32 PM
>> To: Robert Bracknell
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>>
>> LOL! I will be getting one soon. Waiting for Maj Lee to turn it over to m=
>> e after he departs. In the meantime, Hotmail and my IPhone will have to do=
>> !
>>
>> v/r
>> Matt
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Friday, June 03, 2011 13:01
>> To: Mcconnell Maj Matthew N
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sure.
>>
>> (note to self: talk to CDC about getting these guys blackberries)
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Mcconnell Maj Matthew N [matthew.n.mcconnell@usmc.mil]
>> Sent: Friday, June 03, 2011 12:22 PM
>> To: Robert Bracknell
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>>
>> If you send out e-mails this weekend, would you please include my personal =
>> address? mcconnellmn@hotmail.com
>>
>> Thanks.
>> v/r
>> Matt
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Friday, June 03, 2011 10:42
>> To: Hoover Capt Christopher M
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> OK, to recap:
>>
>> Monday 1300 start time at Lejeune Hall.
>>
>> We take Capt Klay's testimony by phone on Tuesday morning after about 1000 =
>> (Quantico hosts conference call) unless I can prevail on his chain of comma=
>> nd to make him available by phone on Monday. TC: I need Captain Klay's tr=
>> aining OIC's phone number and email soonest, please, along with conference =
>> call dial-in instructions, if you have access to that service, or the plan =
>> for getting everyone on the hook with a Quantico-initiated call ("dial-out"=
>> conference call).
>>
>> Please check email a couple of times over the weekend for final plan.
>>
>> s/f,
>> rgb
>>
>>
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> Illegitimi non carborundum
>>
>>
>> -----Original Message-----
>> From: Hoover Capt Christopher M [mailto:christopher.hoover@usmc.mil]
>> Sent: Thursday, June 02, 2011 5:50 PM
>> To: Robert Bracknell
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>> I can follow up with Capt Klay to find out the chain of command.
>>
>> Captain Christopher M. Hoover, USMC
>> Military Justice Officer MCB Quantico
>> Work: (703) 784-0037
>> Cell: (603) 809-5781
>>
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Thursday, June 02, 2011 17:39
>> To: Hoover Capt Christopher M
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Probably -- can you host the teleconference?
>>
>> I say "probably" because I don't quite know yet what Tuesday holds. At the=
>> expense of sounding self-important, I am supposed to go to the White House=
>> Tuesday morning to a reception welcoming Germany Chancellor Merkel. I don=
>> 't know whether our invitation is approved yet, or what time. I will try t=
>> o find out this afternoon/tomorrow. If not, I can leave the investigation =
>> open and provide some teleconference time options.
>>
>> What TAD is Captain Klay conducting, and would it be helpful for me to cont=
>> act whatever Colonel is running the training to get him exempted for an hou=
>> r or two to meet our schedule?
>>
>> s/f,
>> rgb
>>
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Hoover Capt Christopher M [christopher.hoover@usmc.mil]
>> Sent: Thursday, June 02, 2011 5:08 PM
>> To: Robert Bracknell
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Gentlemen,
>> Having issues with availability for Capt Klay.
>>
>> "From Monday is live fire. Can I testify tuesday? I think I can testify a=
>> ny time Tuesday up until 1200. Testifying before 1000 on Tuesday would ena=
>> ble me to not miss anything, including pt. Monday is very bad and uncertai=
>> n. In the worst case, I might be able to testify before 8:00 (on Monday)."
>>
>> Would it be possible to have a teleconference on Tuesday morning for Capt K=
>> lay's testimony?
>> Respectfully,
>>
>> Captain Christopher M. Hoover, USMC
>> Military Justice Officer MCB Quantico
>> Work: (703) 784-0037
>> Cell: (603) 809-5781
>>
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Thursday, June 02, 2011 7:45
>> To: Mcconnell Maj Matthew N
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Roger, 1300 aye. Thanks.
>>
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Mcconnell Maj Matthew N [matthew.n.mcconnell@usmc.mil]
>> Sent: Thursday, June 02, 2011 7:43 AM
>> To: Robert Bracknell
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>>
>> My parents in-law will be getting a nice dinner in the city on me for this =
>> one. They agreed to rearrange their schedule/Dr. appts/etc. (no easy feat =
>> for folks in their 70s) and will be staying at our house for another few da=
>> ys to care for my daughter. So, I'm in for the 1300 start time on Monday w=
>> ith no issues of an early departure looming.
>>
>> v/r
>> Matt
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Wednesday, June 01, 2011 19:00
>> To: Mcconnell Maj Matthew N
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Roger all, standing by.
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Mcconnell Maj Matthew N [matthew.n.mcconnell@usmc.mil]
>> Sent: Wednesday, June 01, 2011 5:18 PM
>> To: Robert Bracknell
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>>
>> My drop-dead time would be 1600 departure for the CDC if in-laws are not ab=
>> le continue child care duties until Monday. I already called my wife about=
>> this and I should be able to let everyone know by tomorrow what the story =
>> is. If they are able to stay, then I would have no problems remaining at t=
>> he 32 until complete.
>>
>> v/r
>> Matt
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Wednesday, June 01, 2011 16:42
>> To: Mcconnell Maj Matthew N; Haytham Faraj; Hoover Capt Christopher M
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> That may trump my teacher meeting. I'm not creating a situation in which t=
>> he accused is essentially forced to go without the assistance of his detail=
>> ed defense counsel, or (as a dad of 5) an expectant Marine mom is home on b=
>> ed rest without help from her husband. So:
>>
>> 1. Matt, what's your end of day "drop dead" time? Fill in the blank: I n=
>> eed to leave Quantico by _______.
>> 2. Let's hold 1300 for now, but please hold your morning free for a possib=
>> le 0800 start time.
>> 3. Matt, please advise when you know more about whether you will have outs=
>> ourced assistance on Monday (in laws) which pushes your drop dead time to l=
>> ater in the evening.
>>
>> S/f
>> Rgb
>>
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Mcconnell Maj Matthew N [matthew.n.mcconnell@usmc.mil]
>> Sent: Wednesday, June 01, 2011 4:17 PM
>> To: Robert Bracknell; Haytham Faraj; Hoover Capt Christopher M
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> LtCol Bracknell, Gentlemen,
>>
>> The only issue I have with starting the 32 at 1300 is that my wife is on be=
>> d-rest (she's due in 4 weeks). So, I may have to depart "early" IOT help h=
>> er with our 18-month-old daughter. We may still have the assistance of my =
>> in-laws on the 6th, and if so, this would not be an issue. If they are not=
>> able to stay past this Saturday (which right now is unknown), then I may h=
>> ave to deal with daycare/getting my daughter in bed, etc. b/c my wife is of=
>> course unable to do any of that. Thanks for your understanding and hopefu=
>> lly my wife's parents will still be here.
>>
>> Sir, BTW, as an Englishman myself (by birth and family line) I of course am=
>> also a fan of the Royal Navy. But does it get much cooler than the USS Fi=
>> rebolt?
>>
>> v/r
>> Maj McConnell
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Wednesday, June 01, 2011 12:32
>> To: Haytham Faraj; Hoover Capt Christopher M
>> Cc: Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> OK, 1300 it is. I will go as late as required to finish. If I were a ship=
>> , I'd be the HMS Indefatigable. Of course, I'd be in the Royal Navy, becau=
>> se only the Brits christen their vessels with such cool names.
>>
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Haytham Faraj [haytham@puckettfaraj.com]
>> Sent: Wednesday, June 01, 2011 12:29 PM
>> To: Robert Bracknell; 'Hoover Capt Christopher M'
>> Cc: 'Mcconnell Maj Matthew N'
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>> Thank you for your consideration of my schedule. I am prepared to start at
>> 1300 so long as we are able to go late until we finish on Monday. I left
>> the morning of the 7th open but I have to be out of Quantico by 1000.
>>
>>
>>
>> -----Original Message-----
>> From: Robert Bracknell [mailto:rbracknell@acus.org]
>> Sent: Wednesday, June 01, 2011 12:22 PM
>> To: Hoover Capt Christopher M
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>> Importance: High
>>
>> Men:
>> As it stands, I see we are going to hear from about 3 or 4 witnesses -- Lt
>> Klay, Cpl Quinn, NCIS SA Buckmon, and possibly Captain Klay -- so a decent
>> ballpark estimate on the length of the hearing is probably somewhere in the
>> neighborhood of 3-8 hours. I need to know whether starting the hearing at
>> 1300 vice a morning start time is going to pose an insurmountable problem
>> for any of you. I have a family obligation (appointment at my daughter's
>> school) first thing Monday morning. Starting at 1300 would enable me to
>> keep the appointment, which has been very difficult to schedule with this
>> particular teacher -- so I'm somewhat reluctant to tell her I can't meet
>> Monday morning. I will if I must, but I'd prefer to work around it.
>>
>> To be frank, I am more concerned with Mr. Faraj's schedule than the two
>> uniformed attorneys or the witnesses. Uniformed Marines (and NCIS agents)
>> get paid to be flexible about nonstandard duty hours. Mr. Faraj, if the
>> hearing lasted from 1300 until 2100, would that adversely affect your
>> calendar for Tuesday 7 June?
>>
>> s/f,
>> LtCol Bracknell
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Robert Bracknell
>> Sent: Wednesday, June 01, 2011 11:18 AM
>> To: Hoover Capt Christopher M
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> My email of May 23 asked you where the witnesses are located. Your reply
>> email of May 24 did not answer this question. It's difficult for me to mak=
>> e
>> a determination since I don't know for certain where the witnesses are. I
>> *assume* Quinn is still at MBW, and that the NCIS agent is still local as
>> well. Where is Captain Klay (spouse) assigned?, and what are his duties?
>>
>> *IF* Quinn and SA Buckmon are local (within 50 miles of Quantico), please
>> produce them. I will decide on Captain Klay today when I learn where he is
>> assigned. If he is no longer local, I may still want to hear from him by
>> phone.
>>
>> Butch Bracknell
>> Lieutenant Colonel of US Marines
>> CMC Fellow, The Atlantic Council
>> o 202-778-4979
>> c 757-287-4704
>> ________________________________________
>> From: Hoover Capt Christopher M [christopher.hoover@usmc.mil]
>> Sent: Wednesday, June 01, 2011 9:53 AM
>> To: Robert Bracknell
>> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
>> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
>>
>> Sir,
>> Has there been a decision regarding witnesses for the Art 32 on 6 Jun?
>> The government intends to call Lt Klay. You stated that once you read the
>> investigation that you would make a determination for SA Buckmon, Cpl Quinn=
>> ,
>> and Capt Klay.
>> Respectfully,
>>
>> Captain Christopher M. Hoover, USMC
>> Military Justice Officer MCB Quantico
>> Work: (703) 784-0037
>> Cell: (603) 809-5781
>>
>>
>> -----Original Message-----
>> From: Mcconnell Maj Matthew N
>> Sent: Thursday, May 26, 2011 18:36
>> To: rbracknell@acus.org
>> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
>> Subject: Re: US v. Rowe - Art 32 Witness Request
>>
>> LtCol Bracknell,
>>
>> Sir, as you requested, please find attached the defense request for
>> production of witnesses for Capt Rowe's Article 32. Also, this afternoon
>> the defense received from Trial Counsel the audio of the pretext phone call
>> between 1stLt Klay and Capt Rowe.
>>
>> V/R
>> Matt
>>
>> Matthew N. McConnell
>> Major, USMC
>> Defense Counsel
>> Office of the Staff Judge Advocate
>> 3250 Catlin Ave, RM 30
>> Quantico, VA 22134
>> Comm: 703-432-4615
>> Fax: 703-784-0259
> <2011-06-06 17.13.06.jpg>
> <2011-06-06 17.13.21.jpg>
> <2011-06-06 17.13.38.jpg>
> <2011-06-06 17.13.52.jpg>
> <2011-06-06 17.14.06.jpg>
Attachment:
Additional Member Questionnaire (Art 120).doc
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