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Re: US v. Rowe - Art 32 Witness Request



Capt Rowe will excuse Maj McConnell if he must leave. 

Sent from my iPad

On Jun 1, 2011, at 4:41 PM, Robert Bracknell <rbracknell@acus.org> wrote:

> That may trump my teacher meeting.  I'm not creating a situation in which the accused is essentially forced to go without the assistance of his detailed defense counsel, or (as a dad of 5) an expectant Marine mom is home on bed rest without help from her husband.  So:
> 
> 1.  Matt, what's your end of day "drop dead" time?  Fill in the blank:  I need to leave Quantico by _______.
> 2.  Let's hold 1300 for now, but please hold your morning free for a possible 0800 start time.
> 3.  Matt, please advise when you know more about whether you will have outsourced assistance on Monday (in laws) which pushes your drop dead time to later in the evening.
> 
> S/f
> Rgb
> 
> 
> Butch Bracknell
> Lieutenant Colonel of US Marines
> CMC Fellow, The Atlantic Council
> o 202-778-4979
> c 757-287-4704
> ________________________________________
> From: Mcconnell Maj Matthew N [matthew.n.mcconnell@usmc.mil]
> Sent: Wednesday, June 01, 2011 4:17 PM
> To: Robert Bracknell; Haytham Faraj; Hoover Capt Christopher M
> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
> 
> LtCol Bracknell, Gentlemen,
> 
> The only issue I have with starting the 32 at 1300 is that my wife is on bed-rest (she's due in 4 weeks).  So, I may have to depart "early" IOT help her with our 18-month-old daughter.  We may still have the assistance of my in-laws on the 6th, and if so, this would not be an issue.  If they are not able to stay past this Saturday (which right now is unknown), then I may have to deal with daycare/getting my daughter in bed, etc. b/c my wife is of course unable to do any of that.  Thanks for your understanding and hopefully my wife's parents will still be here.
> 
> Sir, BTW, as an Englishman myself (by birth and family line) I of course am also a fan of the Royal Navy.  But does it get much cooler than the USS Firebolt?
> 
> v/r
> Maj McConnell
> 
> -----Original Message-----
> From: Robert Bracknell [mailto:rbracknell@acus.org]
> Sent: Wednesday, June 01, 2011 12:32
> To: Haytham Faraj; Hoover Capt Christopher M
> Cc: Mcconnell Maj Matthew N
> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
> 
> OK, 1300 it is.  I will go as late as required to finish.  If I were a ship, I'd be the HMS Indefatigable.  Of course, I'd be in the Royal Navy, because only the Brits christen their vessels with such cool names.
> 
> 
> Butch Bracknell
> Lieutenant Colonel of US Marines
> CMC Fellow, The Atlantic Council
> o 202-778-4979
> c 757-287-4704
> ________________________________________
> From: Haytham Faraj [haytham@puckettfaraj.com]
> Sent: Wednesday, June 01, 2011 12:29 PM
> To: Robert Bracknell; 'Hoover Capt Christopher M'
> Cc: 'Mcconnell Maj Matthew N'
> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
> 
> Sir,
> Thank you for your consideration of my schedule.  I am prepared to start at
> 1300 so long as we are able to go late until we finish on Monday.  I left
> the morning of the 7th open but I have to be out of Quantico by 1000.
> 
> 
> 
> -----Original Message-----
> From: Robert Bracknell [mailto:rbracknell@acus.org]
> Sent: Wednesday, June 01, 2011 12:22 PM
> To: Hoover Capt Christopher M
> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
> Importance: High
> 
> Men:
> As it stands, I see we are going to hear from about 3 or 4 witnesses -- Lt
> Klay, Cpl Quinn, NCIS SA Buckmon, and possibly Captain Klay -- so a decent
> ballpark estimate on the length of the hearing is probably somewhere in the
> neighborhood of 3-8 hours.  I need to know whether starting the hearing at
> 1300 vice a morning start time is going to pose an insurmountable problem
> for any of you.  I have a family obligation (appointment at my daughter's
> school) first thing Monday morning.  Starting at 1300 would enable me to
> keep the appointment, which has been very difficult to schedule with this
> particular teacher -- so I'm somewhat reluctant to tell her I can't meet
> Monday morning.  I will if I must, but I'd prefer to work around it.
> 
> To be frank, I am more concerned with Mr. Faraj's schedule than the two
> uniformed attorneys or the witnesses.  Uniformed Marines (and NCIS agents)
> get paid to be flexible about nonstandard duty hours.  Mr. Faraj, if the
> hearing lasted from 1300 until 2100, would that adversely affect your
> calendar for Tuesday 7 June?
> 
> s/f,
> LtCol Bracknell
> 
> Butch Bracknell
> Lieutenant Colonel of US Marines
> CMC Fellow, The Atlantic Council
> o 202-778-4979
> c 757-287-4704
> ________________________________________
> From: Robert Bracknell
> Sent: Wednesday, June 01, 2011 11:18 AM
> To: Hoover Capt Christopher M
> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
> 
> My email of May 23 asked you where the witnesses are located.  Your reply
> email of May 24 did not answer this question.  It's difficult for me to make
> a determination since I don't know for certain where the witnesses are.  I
> *assume* Quinn is still at MBW, and that the NCIS agent is still local as
> well.  Where is Captain Klay (spouse) assigned?, and what are his duties?
> 
> *IF* Quinn and SA Buckmon are local (within 50 miles of Quantico), please
> produce them.  I will decide on Captain Klay today when I learn where he is
> assigned.  If he is no longer local, I may still want to hear from him by
> phone.
> 
> Butch Bracknell
> Lieutenant Colonel of US Marines
> CMC Fellow, The Atlantic Council
> o 202-778-4979
> c 757-287-4704
> ________________________________________
> From: Hoover Capt Christopher M [christopher.hoover@usmc.mil]
> Sent: Wednesday, June 01, 2011 9:53 AM
> To: Robert Bracknell
> Cc: haytham@puckettfaraj.com; Mcconnell Maj Matthew N
> Subject: RE: Re: US v. Rowe - Art 32 Witness Request
> 
> Sir,
>  Has there been a decision regarding witnesses for the Art 32 on 6 Jun?
> The government intends to call Lt Klay.  You stated that once you read the
> investigation that you would make a determination for SA Buckmon, Cpl Quinn,
> and Capt Klay.
> Respectfully,
> 
> Captain Christopher M. Hoover, USMC
> Military Justice Officer MCB Quantico
> Work: (703) 784-0037
> Cell: (603) 809-5781
> 
> 
> -----Original Message-----
> From: Mcconnell Maj Matthew N
> Sent: Thursday, May 26, 2011 18:36
> To: rbracknell@acus.org
> Cc: Hoover Capt Christopher M; haytham@puckettfaraj.com
> Subject: Re: US v. Rowe - Art 32 Witness Request
> 
> LtCol Bracknell,
> 
> Sir, as you requested, please find attached the defense request for
> production of witnesses for Capt Rowe's Article 32.  Also, this afternoon
> the defense received from Trial Counsel the audio of the pretext phone call
> between 1stLt Klay and Capt Rowe.
> 
> V/R
> Matt
> 
> Matthew N. McConnell
> Major, USMC
> Defense Counsel
> Office of the Staff Judge Advocate
> 3250 Catlin Ave, RM 30
> Quantico, VA 22134
> Comm: 703-432-4615
> Fax:  703-784-0259