Re: Request for a 39a; U.S. v. Rowe

[Haytham Faraj <haytham@puckettfaraj.com>]

Your honor,
Capt Rowe is available.  I think it may be advisable to do this on the record. 

Haytham Faraj 
Sent from my iPhone

On Nov 7, 2011, at 7:34 AM, "Hoover Maj Christopher M" <christopher.hoover@usmc.mil> wrote:

> Gentlemen,
>  It just occurred to me that a 39(a) will require the presence of the accused.  He is located in Oklahoma.  I would ask to handle whatever we can in an 802 so that we do not have to delay any decisions waiting for an accused to fly here.
> Respectfully,
> 
> Major Christopher M. Hoover
> Military Justice Officer 
> Marine Corps Base Quantico
> (703) 432-0488 (office)
> (603) 809-5781 (cell)
> 
> 
> -----Original Message-----
> From: Hoover Maj Christopher M 
> Sent: Monday, November 07, 2011 6:50
> To: Haytham Faraj; 'Hale, Charles C LtCol TRIJUDACT, NDW'
> Cc: 'Hoey, Jeffrey T Sgt TRIJUDACT, WNYD'; Combe Capt Peter C; Mcconnell Major Matthew N
> Subject: RE: Request for a 39a; U.S. v. Rowe
> 
> Sir,
>  The government respectfully requests that the court entertain a 39(a) as early as possible.  The defense is likely going to request another continuance.  The government needs an answer as soon as possible as we have members, courtrooms, and witnesses to coordinate.
> Respectfully,
> 
> Major Christopher M. Hoover
> Military Justice Officer 
> Marine Corps Base Quantico
> (703) 432-0488 (office)
> (603) 809-5781 (cell)
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
> Sent: Friday, November 04, 2011 16:20
> To: 'Hale, Charles C LtCol TRIJUDACT, NDW'
> Cc: 'Hoey, Jeffrey T Sgt TRIJUDACT, WNYD'; Combe Capt Peter C; Hoover Maj Christopher M; Mcconnell Major Matthew N
> Subject: Request for a 39a; U.S. v. Rowe
> 
> Your honor,
> The defense respectfully requests a 39a for Monday November 7 or Tuesday Nov
> 8.  The purpose of the request is to take up a defense motion to relieve
> detailed defense counsel.  The reason the relief of counsel is necessary is
> due to an imputed disqualification of counsel arising from a conflict.  Maj
> McConnell can provide more information on the matter once we get on the
> record.  Trial counsel have been notified.
> 
> Vr,
> 
> Haytham Faraj, Esq.
> PUCKETT & FARAJ, PC
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