Neal, Meant to send attached continuance out Friday. Please sign and scan back to me; if I see Meridith today I'll get her to sign her block too. Doug -----Original Message----- From: Andrew Huff [mailto:landrewhuff@pol.net] Sent: Saturday, January 29, 2011 5:07 AM To: Puckett Neal Cc: Marshall Maj Meridith L; Faraj Haytham; Hatch MAJ Douglas C Subject: Re: Bell case I would likely be available the last week of March also. As always, my boss has to approve. Col Huff ----- Original Message ----- From: "Puckett Neal" <neal@puckettfaraj.com> To: "Hatch MAJ Douglas C" <douglas.hatch@usmc.mil> Cc: "Marshall Maj Meridith L" <meridith.marshall@usmc.mil>, "Faraj Haytham" <haytham@puckettfaraj.com> Sent: Friday, January 28, 2011 1:26:12 PM GMT -05:00 US/Canada Eastern Subject: Re: Bell case I'm available the last week in March. Give me a bit to check with Dr. Huff for his availability. If he's open then we can make it that week. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jan 28, 2011, at 12:55 PM, Hatch MAJ Douglas C wrote: The latest long range is attached. I'm free the last week of March (Alire is pleading). It looks like the earliest that Meridith and I are freed up after that is 9 May. Wutterich is killing us. The CA would not entertain 24 years when we informed him that you had floated that proposal. I'm pretty sure I can get him to agree to 28. -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Friday, January 28, 2011 9:42 AM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Re: Bell case Doug, I don't have any visibility on the Circuit docket. Can you look at that and propose some dates with a view toward negotiating a PTA? I'm still in the market for a deal in the vic of 24 years. S/f, Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jan 28, 2011, at 12:33 PM, Hatch MAJ Douglas C wrote: Current dates are 14-18 Feb. The CO just signed off on the expert request. Hoping the travel piece works out. -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Friday, January 28, 2011 8:58 AM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Re: Bell case Doug, Can do. What's the current date scheduled? Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jan 28, 2011, at 11:47 AM, Hatch MAJ Douglas C wrote: Neal, Meridith is out of the office, and I never received a continuance request. I can draft a continuance request for your signature, but I'll need some dates from you. S/F Doug -----Original Message----- From: Neal Puckett [mailto:neal@puckettfaraj.com] Sent: Thursday, January 27, 2011 5:15 PM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Re: Bell case Doug, Turns out law center will be mire than adequate. Thanks! Just need approval now. Neal A. Puckett LtCol, USMC (Ret) Puckett & Faraj, PC 703.706.9566 Sent from my iPhone On Jan 27, 2011, at 18:48, "Hatch MAJ Douglas C" < douglas.hatch@usmc.mil > wrote: Neal--surprising to me, but the brig will support release on weekend days. GySgt Bell's legal officer is setting up chaser support and they'll be prepared to cart him back and forth from the brig on 4, 5, and 6 Feb, should all other stars align. If Meridith is able to secure the Base clinic, I don't have a problem with the evaluations going there. If she is unable to make that happen, I'll be able to offer up spaces in the law center, such as the library, if Meridith's office is unacceptable. -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Thursday, January 27, 2011 12:00 PM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Re: Bell case Checking. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jan 27, 2011, at 2:52 PM, Hatch MAJ Douglas C wrote: Neal, You're not getting pushback from me. The brig here is notoriously difficult to deal with. Meridith can back me on that. Realistically, Dr. Huff's going to need to give us some alternative dates. I'll do whatever I can to get him approved in time for him to fly out next weekend, however. Doug -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Thursday, January 27, 2011 11:35 AM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Re: Bell case Doug, Below is a copy and paste of his only time available until March. He's booked solid and is having to get special permission for the below dates. We're trying to expedite his participation in this case so "push back" would not be particularly productive on any front, most importantly a hearing date, should we reach agreement on a PTA. I'll work with Meridith to get the continuance to you ASAP. flying out on 3 Feb, evaluating the individual on 4, 5, and 6 Feb and returning to DC on 7 Feb. Actually the better venue would be the base clinic, vice Meridith's office. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jan 27, 2011, at 2:22 PM, Hatch MAJ Douglas C wrote: Neal, Copy all. I can see what I can do about having him brought over to Meridith's office for evaluation over the weekend--is that what you envisioned? Foreseeing likely push back, we will also have to look at options for doing this during the work week. I'll get the endorsement worked up today and try to push it through to the CO as quickly as possible. Please send the continuance along as quickly as possible--I'll concur, but please reference the fact that the continuance is based upon the issues regarding expert assistance. Doug -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Thursday, January 27, 2011 10:48 AM To: Hatch MAJ Douglas C Cc: Marshall Maj Meridith L; Faraj Haytham Subject: Re: Bell case Doug, Ditto. He can come out next weekend and do a full work up (provided he can have clinical access to Bell (vice at the brig) through the weekend. We can be ready pretty quickly for a hearing after that. He has a few hard scheduling items that it won't be too hard to work around. Meantime, I believe a PTA will be coming your way soon. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jan 27, 2011, at 1:45 PM, Marshall Maj Meridith L wrote: Doug, Neal and I have been in contact and I think we can make it work with his schedule. R/ Major Meridith L. Marshall Senior Defense Counsel MCAS, Miramar 858-577-1720 meridith.marshall@usmc.mil -----Original Message----- From: Hatch MAJ Douglas C Sent: Thursday, January 27, 2011 10:35 AM To: Marshall Maj Meridith L Cc: 'Puckett Neal' Subject: RE: Bell case I haven't heard back from Dr. Huff as to his availability (I cc-ed you). Have you tried to contact him yet? I want to know what his availability is before I endorse the expert request. -----Original Message----- From: Marshall Maj Meridith L Sent: Thursday, January 27, 2011 9:57 AM To: Hatch MAJ Douglas C Cc: Puckett Neal Subject: RE: Bell case Doug, There will be a continuance based on our request for Dr. Huff. Where in the pipeline is the request for Dr. Huff? R/ Major Meridith L. Marshall Senior Defense Counsel MCAS, Miramar 858-577-1720 meridith.marshall@usmc.mil -----Original Message----- From: Hatch MAJ Douglas C Sent: Wednesday, January 26, 2011 3:16 PM To: Marshall Maj Meridith L Subject: RE: Bell case Meridith--did you hear back from Neal? What are you planning on doing about a continuance? -----Original Message----- From: Hatch MAJ Douglas C Sent: Monday, January 24, 2011 8:55 AM To: 'Puckett Neal'; Marshall Maj Meridith L Subject: Bell case Importance: High Meridith, Neal, Please advise on the latest on this case. We have witnesses who are re-arranging their schedules based on trial dates of 14-18 February. I also need to start making travel arrangements for these witnesses by the end of the week for those trial dates. I imagine we will be able to work out a deal still. However, I hate the idea of telling folks (civilians) to re-arrange their schedule, then call off the trial at the last minute--whether it's because we deal or because we have to move the trial based on Neil's schedule. Neal--as I understand it, GySgt Bell still has not retained you for the court-martial. Meridith can't put in a continuance request based on your availability until you've been retained. I have trial dates that I need to abide by. I recommend that Meridith put in a continuance now, based on her availability. Because we are working on finding a mental health expert, I can support a continuance for that reason. Of course we can't base that continuance request on Neal's schedule since he's not on the case. If we end up going contested, we'll have to leave it up to the judiciary whether the case can be continued again based on Neal's schedule. If not, we should be able to find a day that works with Neal's schedule for the guilty plea and pre-sentencing hearing. Please let me know what you think. V/R Major Doug Hatch, USMC Military Justice Officer 3d Marine Aircraft Wing & MCAS Miramar (858)577-6859 <SIERRA JUDICIAL DISTRICT L0NG RANGE DOCKET.XLS>
Attachment:
Continuance request (Bell).doc
Description: Continuance request (Bell).doc