Re: US v. Rowe Motion

[Haytham Faraj <haytham@puckettfaraj.com>]

I will not object to you preadmitting the phone call. 

Haytham Faraj
Sent from my iPad

On Nov 17, 2011, at 7:31 AM, "Combe Capt Peter C" <peter.combe@usmc.mil> wrote:

> Mr. Faraj,
> 
> I had intended to have Mrs. Klay and SA Buckmon here for the motion tomorrow to preadmit the recorded phone call.  Based on your email below I don't believe that is necessary.  If you plan not to contest, then I will tell them that there is no need to come in.  Thanks for your cooperation on this.
> 
> Very Respectfully,
> Capt Peter C. Combe II
> Trial Counsel
> Office of the SJA, MCB Quantico
> 3250 Catlin Ave.
> Quantico, VA 22134 
> 
> Comm: (703) 784-0037  DSN: 278
> Fax: (703) 784-0035  DSN: 278
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
> Sent: Thursday, November 10, 2011 12:47
> To: Combe Capt Peter C
> Cc: Shinn Capt Scott R
> Subject: RE: US v. Rowe Motion
> 
> Pete,
> We will not object to your motion.  For future reference, feel free to check
> with me before working on a motion.  If it is not objectionable I will not
> object or will try to work with you.  With respect to this motion, I request
> that the Government also produce the side conversation that was taking place
> between the NCIS Agent and Klay while this recording was taking place.  
> 
> Vr,
> Haytham
> 
> -----Original Message-----
> From: Combe Capt Peter C [mailto:peter.combe@usmc.mil] 
> Sent: Thursday, November 10, 2011 12:27 PM
> To: Hale LtCol Charles C
> Cc: haytham@puckettfaraj.com; jeffrey.hoey@navy.mil
> Subject: US v. Rowe Motion
> 
> Good afternoon Sir,
> 
> Attached is a government motion to preadmit in Rowe.  I have already
> provided the original to the court reporters to be marked as an appellate
> exhibit.
> 
> I know that this government motion is out of time per the original pretrial
> order.  That said, I understood Monday's 802 conference established that
> both defense as well as government motions would be due today.
> 
> If that is not the case, I apologize for my misunderstanding.
> 
> Very Respectfully,
> Peter C. Combe II
> Capt, U.S. Marine Corps
> Trial Counsel
> 
> Office of the Staff Judge Advocate
> Military Justice Office
> Marine Corps Base Quantico
> 3250 Catlin Avenue
> Quantico, VA 22134
> 
> Comm: (703) 784-0037  DSN: 278
> Fax: (703) 784-0035  DSN: 278
> 
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