Sir, An updated defense discovery motion is attached that should meet the intent of your email request. Thank you. Christian P. Hur Captain, USMC Senior Defense Counsel Telephone: (619) 524-8713 Fax: (619) 524-6784 Address: Defense Section, Bldg 12, 1st Floor, MCRD, San Diego, CA 92140 This email may contain Attorney Work Product. Please delete if you received this message in error. -----Original Message----- From: Keane LtCol Stephen F Sent: Monday, September 27, 2010 8:35 To: Hur Capt Christian P; 'Faraj, Haytham'; Torresala Capt John W Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R Subject: RE: Brito Motions Capt Hur: Also, one thing I was going to tell you in the 802 that you can work on now is that you need to file an amendment to your motion to compel, by COB today, clearly and specifically listing the witnesses you are requesting compelled and the justification (proffer of relevance and necessity). I am not going to sift through your discovery requests in an attempt to ascertain who you are requesting. If there is any discovery that you are requesting that is not clearly and specifically articulated in your motion, again I am not inclined to sift through discovery requests and responses to correlate them for you, you must specifically articulate the request in the motion addendum. r/ LtCol Keane -----Original Message----- From: Hur Capt Christian P Sent: Monday, September 27, 2010 8:02 To: Keane LtCol Stephen F; 'Faraj, Haytham'; Torresala Capt John W Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R Subject: RE: Brito Motions 1530 PST with your permission Sir. Christian P. Hur Captain, USMC Senior Defense Counsel Telephone: (619) 524-8713 Fax: (619) 524-6784 Address: Defense Section, Bldg 12, 1st Floor, MCRD, San Diego, CA 92140 This email may contain Attorney Work Product. Please delete if you received this message in error. -----Original Message----- From: Keane LtCol Stephen F Sent: Monday, September 27, 2010 7:54 To: Hur Capt Christian P; 'Faraj, Haytham'; Torresala Capt John W Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R Subject: RE: Brito Motions What time did you arrive at for the 802 conference? R/ LtCol Keane -----Original Message----- From: Hur Capt Christian P Sent: Monday, September 27, 2010 7:30 To: 'Faraj, Haytham'; Keane LtCol Stephen F; Torresala Capt John W Cc: Grisalesmery Cpl Alejandro; Ospina SSgt Jhony A; Rubin LtCol Peter R Subject: FW: Brito Motions Gentlemen, I wanted to be sure you received this email from Mr. Faraj. -Capt Hur -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Sunday, September 26, 2010 17:22 To: Rubin LtCol Peter R Cc: Hur Capt Christian P; 'Mariam Chamesseddine'; Day Capt Evan S Subject: Brito Motions Your honor, We are submitting two additional motions in the U.S. v. Brito. We acknowledge that they are late. Some of the facts in the motions did not develop until after the original motions submission date. Vr, Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone DETROIT METRO 6200 Schaefer Road Suite 202 Dearborn, MI 48126 313-457-1390 Phone 202-280-1039 Fax www.puckettfaraj.com <http://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.
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first Amendment Brito Consolidated Discovery Motion.pdf
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