[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
Re: Defense motion to continue U.S. v. Rowe
Thank you. I appreciate your response. I will work to put something on paper and have it to you by Monday.
Haytham Faraj
Sent from my iPhone
On Oct 27, 2011, at 12:04 PM, "Combe Capt Peter C" <peter.combe@usmc.mil> wrote:
> Mr. Faraj,
>
> We are certainly willing to work with you. I agree that the CG's intent seems to be that Capt Rowe is out of the Marine Corps. If we have a deal that gets us there, then I think both sides should do what we can to favorably endorse that to the CG.
>
> I was not saying that the BOI waiver was an absolute necessity, but thought that was a starting point that had been discussed.
>
> 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, October 27, 2011 11:35
> To: Combe Capt Peter C; Hoover Capt Christopher M
> Cc: Mcconnell Major Matthew N
> Subject: RE: Defense motion to continue U.S. v. Rowe
>
> I recall we discussed an NJP and an immediate unqualified resignation. I
> know that Capt Rowe's career is over. But he is not going to be separated
> at court martial even if you secure a conviction on one of the charges. He
> has an excellent record of service and has been in combat. The members will
> retain him. If a BOI is held after retention by a court-martial they will
> either retain, or separate with a General or Honorable. I can get you there
> if you are willing to work with me. A BOI with a board waiver does not get
> us there. The CG wants him out. I get it. But the CG will waste a lot of
> time working to get him out without a deal. Remember that he suffers from
> severe PTSD and Marine Corps policy requires that he go through a series of
> steps before he is separated and certainly not with an OTH. I know you and
> Capt Hoover do not have much discretion in what happens but I hope you can
> work with the SJA and the CA to make them understand that we can both get to
> our objectives without taking inflexible positions.
>
> -----Original Message-----
> From: Combe Capt Peter C [mailto:peter.combe@usmc.mil]
> Sent: Thursday, October 27, 2011 10:44 AM
> To: Haytham Faraj; Hoover Capt Christopher M
> Cc: Mcconnell Major Matthew N
> Subject: RE: Defense motion to continue U.S. v. Rowe
>
> Mr. Faraj,
>
> The deal that we had previously discussed was an NJP to the adultery,
> indecent act, conduct unbecoming type offenses with a BOI waiver.
>
> If that is what you are asking, then yes, those are the terms we believe are
> in the ballpark.
>
> 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, October 27, 2011 10:34
> To: Hoover Capt Christopher M
> Cc: Mcconnell Major Matthew N; Combe Capt Peter C
> Subject: RE: Defense motion to continue U.S. v. Rowe
>
> Is this under the same terms that we previously discussed?
>
> -----Original Message-----
> From: Hoover Capt Christopher M [mailto:christopher.hoover@usmc.mil]
> Sent: Thursday, October 27, 2011 8:09 AM
> To: Haytham Faraj
> Cc: Mcconnell Major Matthew N; Combe Capt Peter C
> Subject: RE: Defense motion to continue U.S. v. Rowe
>
> Gentlemen,
> We will not be requesting another deposition for Jeremy Owens. We already
> have 90% of his testimony sworn from his first deposition. Immunity has
> been provided through the DOJ, so Owens is available for interviews. We
> have already spoken with him this morning.
> The SJA for the CG has indicated that they will entertain offers for a
> deal at this point. I would recommend submitting a deal ASAP. The
> indication is that there is a good chance that we will be trying this case.
> If you provide a deal now, we can work on getting approval. If the deal is
> untimely, then it is hard to sell approval if we are rushed. I would think
> that you would also like to know if you have a deal or not, so you can
> prepare if required.
>
> Captain Christopher M. Hoover
> Military Justice Officer
> Marine Corps Base Quantico
> (703) 432-0488 (office)
> (603) 809-5781 (cell)
>
>
> -----Original Message-----
> From: Hale LtCol Charles C
> Sent: Wednesday, October 26, 2011 10:11
> To: 'Haytham Faraj'; Hoover Capt Christopher M; Combe Capt Peter C
> Cc: Mcconnell Major Matthew N; Miller Sgt Dan R; Presley Sgt Zane A; Hansen
> Cpl Logan R; 'Hoey, Jeffrey T Sgt TRIJUDACT, WNYD'
> Subject: RE: Defense motion to continue U.S. v. Rowe
>
> Counsel,
>
> Government response to the defense motion to continue is due by 0730 27 Oct
> 2011.
>
> Charles C. Hale
> Lieutenant Colonel, U.S. Marine Corps
> Circuit Military Judge
> Northern Judicial Circuit
> Bldg 200, 1250 10th St SE Suite 1300
> Washington Navy Yard, DC 20374
> http://auth.cnic.navy.mil/NDW/RegionNews/CourtDockets/NorthernJudicialCircui
> t/
> Phone: (202) 685-5893 Direct Line 202-685-5897 Quantico Judge's Chambers
> 703-432-2369
> Fax: (202) 685-5895
> charles.c.hale@navy.mil
>
>
>
>
>
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Wednesday, October 26, 2011 9:34
> To: Hale LtCol Charles C
> Cc: Mcconnell Major Matthew N; Miller Sgt Dan R; Presley Sgt Zane A; Hansen
> Cpl Logan R; jeffrey.hoey@navy.mil
> Subject: Defense motion to continue U.S. v. Rowe
>
> Your honor,
> The defense motion is attached.
>
>
> Vr,
>
> Haytham Faraj, Esq.
> PUCKETT & FARAJ, PC
> _______________________
> WASHINGTON DC METRO
> The Law Firm of Puckett & Faraj, PC
> 1800 Diagonal Road
> Suite 210
> Alexandria, VA 22314
> 703-706-0442 Phone
> 202-280-1039 Fax
>
> DETROIT METRO
> The Law Firm of Puckett & Faraj, PC
> 835 Mason Street
> Suite 150-A
> Dearborn, MI 48124
> 313-457-1390 Phone
> 202-280-1039 Fax
>
>
> 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.
>
>
>
>