Re: Lopez: Witness documents

[Haytham <haytham@puckettfaraj.com>]

Yes. Next week is good. 

Haytham Faraj 
Sent from my iPhone

On Apr 20, 2011, at 8:45 AM, "White Capt Bret A" <bret.a.white@usmc.mil> wrote:

> LtCol Robinson called me.  I told him that we really just want to move the motions deadline and want to be able to give trial counsel enough time to respond before the 39a on 5 May.  I'd propose that middle of next week for our deadline is good and their response can be as late as the day before the 39a, 4 May.  Let me know your take on it and I'll push it to the TC.  LtCol Robinson said that he's good with whatever we agree to on moving the motions and response dates.
> 
> S/f,
> 
> Bret
> 
> -----Original Message-----
> From: Haytham [mailto:haytham@puckettfaraj.com] 
> Sent: Wednesday, April 20, 2011 8:14
> To: White Capt Bret A
> Subject: Re: Lopez: Witness documents
> 
> Just email the judge and say we want a telephonic 802. 
> 
> Haytham Faraj 
> Sent from my iPhone
> 
> On Apr 20, 2011, at 3:44 AM, "White Capt Bret A" <bret.a.white@usmc.mil> wrote:
> 
>> Roger.  I'll let Capt Combe know we want an 802.  Capt Tilney is at home today.
>> 
>> -----Original Message-----
>> From: Haytham [mailto:haytham@puckettfaraj.com] 
>> Sent: Wednesday, April 20, 2011 1:33
>> To: White Capt Bret A
>> Subject: Re: Lopez: Witness documents
>> 
>> Let's ask for an 802 conference. I can try to draft a quick motion. 
>> 
>> Haytham Faraj 
>> Sent from my iPhone
>> 
>> On Apr 19, 2011, at 3:31 PM, "White Capt Bret A" <bret.a.white@usmc.mil> wrote:
>> 
>>> Haytham,
>>> 
>>> I had some computer issues earlier and then neglected to send this to you.  I've attached the relevant witness correspondence with TC's response.  
>>> 
>>> Also, I checked with Capt Tilney and he is not interested in moving the motions, response, 39a, and Pg 56 to 7 days later, as we did with the trial.  So, he is saying he won't agree to submitting a joint modified PTO.  What do you think - should we file a motion to modify the PTO?  On what basis?
>>> 
>>> I'm buckling down for my trial tomorrow, but I'll be in the office.
>>> 
>>> V/r,
>>> 
>>> Bret A. White
>>> Captain, U.S. Marine Corps
>>> Defense Counsel
>>> 
>>> Office of the Staff Judge Advocate
>>> Marine Corps Base               
>>> 3250 Catlin Avenue                            
>>> Quantico, VA 22134                           
>>> 
>>> Main:    703.784.4615/4628
>>> Direct:  703.784.0405
>>> Fax:     703.784.0259
>>> 
>>> 
>>> <Lopez_Witness List for CinC.docx>
>>> <Lopez_Witness List for CinC.PDF>
>>> <Lopez_OOA Witness Request.PDF>
>>> <Lopez_TC Response to OOA Witness Req.PDF>
>>> <Lopez_Witness List w OOA Witnesses.docx>