RE: US v. Rowe

[Haytham Faraj <haytham@puckettfaraj.com>]

Gentlemen,

Here are my proposed dates:

Trial to start on March 5, 2012

All discovery and notices pursuant to RCM 701, 301, 304, 311, 321, 413(b),
and 414(b) due on January 4 2012

Request for Defense expert January 9, 2012

Witness request February 13, 2012

Motions due February 6, 2012

Article 39a February 21, 2012

Page 56 matter due February 24, 2012

The purpose of the date in March is because I am scheduled to be in the
Haditha trial from January 4-31.  The entire month of December will be
dedicated to preparing for that case.  

While the month of November has some white space for me, I don't think
either side will realistically be ready for trial given the continued work
on Mr. Owens and some of the other logistical matters that remain to be
done. I am open to discussing it, however.

Vr,
Haytham Faraj

-----Original Message-----
From: Combe Capt Peter C [mailto:peter.combe@usmc.mil] 
Sent: Thursday, October 20, 2011 12:00 PM
To: Haytham Faraj
Subject: RE: US v. Rowe

Good afternoon Sir,

I was looking to call you but don't have a phone number.  I was curious as
to whether you were looking at new trial dates, etc.

I am asking because we are looking at setting up travel and what-not and
would like like to know about new dates before we do so.

Thanks for your time,
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: Wednesday, October 19, 2011 9:14
To: Mcconnell Major Matthew N
Cc: Combe Capt Peter C
Subject: Re: US v. Rowe

I have some new proposed dates I will send you today. 

Haytham Faraj 
Sent from my iPhone

On Oct 18, 2011, at 4:29 PM, "Mcconnell Major Matthew N"
<matthew.n.mcconnell@usmc.mil> wrote:

> Pete,
> 
> Understand.  What about Jeremy?  Has he been granted testimonial immunity
at this point?  If so, are you going to ask for another deposition?
> 
> s/f
> Maj McConnell 
> 
> -----Original Message-----
> From: Combe Capt Peter C 
> Sent: Tuesday, October 18, 2011 7:53
> To: haytham@puckettfaraj.com; Mcconnell Major Matthew N
> Subject: US v. Rowe
> Importance: High
> 
> Gentlemen,
> 
> Attached is notice that the government is in the process of contracting an
expert in the field of forensic psychology.
> 
> My apologies for the late notice.  The government will not oppose any
motion raised by this action on grounds of timeliness, but reserves the
right to contest any motion on any other grounds.
> 
> 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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