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Gentlemen,
Attached is a preliminary first draft of the Wuterich writ appeal. I
still have to do considerable work on it, but at least it's now in the proper
format and provides a framework from which we can all work. Let's do what we did
last week and make all changes in either track changes format or in comment
bubbles. I can then add everyone's changes to the master draft tomorrow
night so we don't have multiple iterations floating around.
Once again I've inserted comments soliciting particular information.
I still don't have a copy of the final version that we filed at NMCCA, so some
of the questions replicate questions asked last week.
Haytham, could you please reinsert the language you provided on last week's
draft pointing out where Judge Jones' factual findings were wrong?
And Maj Sip, can you please add in that great language from NMCCA's
Hutchins opinion that you pulled out?
Tomorrow night I'm going to mine the Hutchins briefs, the Hutchins oral
argument, and CAAF's Iverson opinion for anything we should add. Maj Sip,
do you think there's any chance that Babu might be willing to look at this draft
and provide suggestions? If so, could you please ask him? (It might
be a conflict of interest for him to do so; if so, we shouldn't ask and if we do
ask, we should make clear that we don't expect him to be able to review it if he
is conflicted.)
Semper Fi,
DHS |
Attachment:
Wuterich writ appeal.doc
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