Re: Lopez Motions

[Haytham <haytham@puckettfaraj.com>]

Can you talk this morning?

Haytham Faraj 
Sent from my iPhone

On Apr 19, 2011, at 5:19 AM, "White Capt Bret A" <bret.a.white@usmc.mil> wrote:

> Haytham,
> 
> I will submit a request to move all the remaining deadlines (motions, responses, 39a, and pg56 matters) by one week since the trial is moving one week, too.  What's your availability for a 39a on 12 May or one day to the left or right?
> 
> I have submitted requests for out of area witnesses.  Are you referring to requesting witnesses like the TBS students and others who may not come willingly?  Also, they denied our initial request to bring in all of the remaining (38) officer candidates from out of area who did not graduate and go on to TBS.  I think my request was lacking in the 'synopsis of testimony' category, or at least that's the claim.
> 
> Let me know what needs to be done there.
> 
> S/f,
> 
> Bret
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
> Sent: Tuesday, April 19, 2011 0:54
> To: White Capt Bret A
> Subject: RE: Lopez Motions
> 
> Bret,
> I am in a 118 Article 32 that is expected to last the rest of the week.  I
> unfortunately will have no time to put motions together and frankly don't
> know what motions we should file at this point.  We need to submit witness
> requests ASAP.  Is it possible to see if we can get another week for
> motions?  Our motions are going to be on legal issues such as dismiss for
> failure to state and offense or vagueness.  I think we may be able to file
> those later if we ask the court for some additional time.
> 
> -----Original Message-----
> From: White Capt Bret A [mailto:bret.a.white@usmc.mil] 
> Sent: Monday, April 18, 2011 2:45 PM
> To: haytham@puckettfaraj.com
> Subject: Lopez Motions
> 
> Haytham,
> 
> I just want to check in on our upcoming motions deadline for this Thursday.
> I'm prepping for two contested trials back-to-back from this Thursday
> through next Tuesday, so I'm focused on those right now.  Can you update me
> on your plans for motions for SSgt Lopez?  
> 
> S/f,
> 
> Bret A. White
> Captain, U.S. Marine Corps
> Defense Counsel
> 
> Office of the Staff Judge Advocate
> Marine Corps Base               
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> 
> Main:    703.784.4615/4628
> Direct:  703.784.0405
> Fax:     703.784.0259
> 
> 
>