RE: Lopez Motions

[Haytham Faraj <haytham@puckettfaraj.com>]

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               
3250 Catlin Avenue                            
Quantico, VA 22134                           

Main:    703.784.4615/4628
Direct:  703.784.0405
Fax:     703.784.0259