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Re: UCI/Wrongful Withdrawal Witness List



Doug,

I edited your request.  I added everyone I could think of along with a
synopsis of what they would say.  Witnesses in bold are my top
choices.

On Tue, Feb 1, 2011 at 1:01 PM, Douglas Wacker <douglas.wacker@gmail.com> wrote:
> We also need to request judge to compel discovery of investigation records.
>
> -dsw
>
> On Feb 1, 2011 12:53 PM, "Douglas Wacker" <douglas.wacker@gmail.com> wrote:
>> Haytham,
>>
>> Here is the list of individuals who have been involved in the case.
>>
>> The issues I see:
>> --Misconduct in investigation and interference with potential witnesses:
>> Blosser, Brooder, Easley, USD Officials.
>> --Interference with ELP Law status and contact with Col Helfrich, SJA to
>> CMC
>> Officials.
>> --PAO news release, how it was unheard of (Steve Liewer), and its
>> distribution to every person on MCRD on three separate days.
>> --LtCol Bond Email and Col Smith statements to G-3 and other personnel;
>> transfer to H&S Bn S-3 (to a position never filled before under Maj
>> Goodpasture) after exercise completion.
>> --Transfer to 3d MAW and ultimate delay in case process in order to avoid
>> UCI, discussions had to be held at the General or CoS level with SJAs and
>> staff involved.
>> ***A transfer to avoid litigating the issue of UCI is wrongful, see J.
>> Effron dissent in U.S. v. Villareal (CAAF 1999).
>>
>> You should be able to link the individuals to the different issues. I
>> expect
>> Col Smith and SA Burge to deny, deny, deny. The other individuals will be
>> able to testify as to what actions/statements were taken by Col Smith and
>> SA
>> Burge.
>>
>> Col White and Capt Pappas were the SJA and officer responsible with filing
>> the ODM matter when this started in Jan 2008 with a phone call from
>> another
>> NCIS agent to Col Helfrich and Capt Woelhoff alerting me to the arrest
>> warrant in NOLA.
>>
>> S/F
>>
>> Doug
>>
>>
>>
>> --
>> Douglas S. Wacker
>> 1719 Adams Ave
>> San Diego, CA 92116
>> 858.401.9392
>



-- 
Christian P. Hur

Attachment: UCI motion witnesses requested.doc
Description: MS-Word document