FW: Rowe reasons for the continuance

["Haytham Faraj" <Haytham@puckettfaraj.com>]

-----Original Message-----
From: Mcconnell Major Matthew N [mailto:matthew.n.mcconnell@usmc.mil] 
Sent: Tuesday, October 25, 2011 7:29 AM
To: Haytham Faraj
Subject: RE: Rowe reasons for the continuance

Good morning Haytham,

I'm literally seconds away from going into a trial this morning, but I
just wanted to drop you a quick response to this e-mail.  I think the Govt
is going to require you to file a motion with the court.  I'm not sure,
but the MO around here has been that they don't accept e-mail requests.
I'm sure you have a ton of them, but if you need an stock motion for
continuance I'll send you one.  I will be checking this account
sporadically over the next few days, so I'll get back to you whenever I am
able.  Thanks Haytham.

s/f
Matt

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Monday, October 24, 2011 17:37
To: Combe Capt Peter C; Hoover Capt Christopher M
Cc: Mcconnell Major Matthew N
Subject: Rowe reasons for the continuance

Gentlemen,

I am writing to request concurrence for a continuance of the Rowe trial.
The trial is currently scheduled to commence on November 1.  I am
requesting that it be continued until March 5, 2012.  The primary purpose
for the lengthy delay is because I am scheduled to for the U.S. v.
Wuterich trial from January 4 until January 31, 2012.  U.S. v. Wuterich is
a case that resulted from the killings of 24 civilians in the town of
Haditha in Iraq on November 19, 2005.  That case has languished due to
lengthy appellate matters that were recently resolved.  The gravity of the
charges in that case and its age require me to invest substantial time to
get ready.  Our firm has, therefore, set aside the month of December to
prepare.  I previously notified Trial Counsel that I would be agreeable to
a date in November.  I am currently available the week of November 14 and
the week of November 28.  While the November dates I proposed are
agreeable, I request that you keep in mind our request to immunize Mr.
Owens and our request for an expert.  So long as those two matters can be
accomplished, I will be available during the two proposed November dates.
The defense will agree that the delay will be excludable.

 

Thank you for consideration of my request

 

Vr,

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

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