Re: Rowe motions

[Haytham Faraj <haytham@puckettfaraj.com>]

Let me get back to you later. I'm about to start an article 32. I trust your judgement. I prefer we get a pleading filed as soon as practicable to be fair. We can always adjust. 

Haytham Faraj 
Sent from my iPhone

On Nov 9, 2011, at 7:04 AM, "Shinn Capt Scott R" <scott.shinn@usmc.mil> wrote:

> Haytham,
>  Here's what I'm thinking...
> 
> For the Multiplicity Argument:
> 
> - Charge I Spec 5 mult. w/ Charge I Spec 1
> - Charge I Spec 2 mult. w/ Charge II
> - Charge II Spec 1 mult. w/ Charge II Spec 2
> - Charge IV mult. w/ Charge VII Spec 3 and Add'tl Charge Spec 2
> - Charge V mult. w/ Charge I
> - Charge VI mult w/ Charge VII Spec 1
> 
> 
> For the UMC Argument:
> 
> Charge I Spec 4 (indecent act) as the umbrella offense for:
> - Charge I Specs 1, 2, 3, and 5
> - Charge III
> - Charge V
> - Charge VI
> - Charge VII Specs 1 and 4 
> - Add'l Charge Spec 2
> 
> Charge III Spec 1 is the umbrella for Spec 2
> 
> Add'l Charge Spec 2 is the umbrella offense for Charge IV
> 
> 
> What do you think?
> 
> ~Russ
> 
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
> Sent: Tuesday, November 08, 2011 20:01
> To: Shinn Capt Scott R
> Subject: Rowe motions
> 
> Russ,
> 
> I would like you to take a close look at the charge sheet and draft a motion to challenge multiplicity and UMC.  I think there are a lot of multiplicious charges or unfair multiplication of charges.  We should be able to kill a few of those before trial.
> 
> 
> 
> Thanks
>