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Re: SSgt Lopez
The payment arrangements are of no relevance. Once ACR forms courts nor the rules concern themselves with payments. This case is going to require sometime consuming interviews and motions practice. I can tell you that I'm unavailable the period of 24-27 May.
I'll provide you a notice of appearance. Have you submitted a discovery request? We'll need an Alpha roster for her platoon and contact information on all members. I know you've already thought of the Bill of Particulars. There is substantial ambiguity in the way the charges are drafted that makes them subject to attack.
Haytham Faraj
Sent from my iPhone
On Mar 31, 2011, at 3:08 PM, "White Capt Bret A" <bret.a.white@usmc.mil> wrote:
> Haytham,
>
> I left you a voicemail. I've spoken with SSgt Lopez and she laid out the arrangement. So, as I understand it, she's planning on getting you 80% next week and the other 20% NLT 30 days before trial. In that case, I'm assuming that you'll file your notice of appearance after receiving the initial %80. So, whenever you're ready, I'm available to discuss the case, what I've done so far, my talks with TC, opinions, etc.
>
> I'll be in the office most of the day Friday, although mornings are always best.
>
> Semper fidelis,
>
>
> 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: 703.784.4628
> Direct: 703.784.4635
> Fax: 703.784.0259
>
>
>
>
>
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Thursday, March 31, 2011 11:15
> To: White Capt Bret A
> Subject: RE: SSgt Lopez
>
> Called your numbers but didn't get any answers.
>
> -----Original Message-----
> From: White Capt Bret A [mailto:bret.a.white@usmc.mil]
> Sent: Thursday, March 31, 2011 10:28 AM
> To: Haytham Faraj
> Subject: RE: SSgt Lopez
>
> Yes. I'll be here. If I'm not answering the 4635 number, please try
> 703-784-4615/4628.
>
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Thursday, March 31, 2011 10:17
> To: White Capt Bret A
> Subject: RE: SSgt Lopez
>
> Can we push to 1100. If not I am available this afternoon at 1330
>
> -----Original Message-----
> From: White Capt Bret A [mailto:bret.a.white@usmc.mil]
> Sent: Wednesday, March 30, 2011 6:28 PM
> To: Haytham
> Subject: RE: SSgt Lopez
>
> That works for me. Talk to you then.
>
> Respectfully,
>
> 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: 703.784.4628
> Direct: 703.784.4635
> Fax: 703.784.0259
>
>
>
>
>
> -----Original Message-----
> From: Haytham [mailto:haytham@puckettfaraj.com]
> Sent: Wednesday, March 30, 2011 18:11
> To: White Capt Bret A
> Subject: Re: SSgt Lopez
>
> I apologize I couldn't finish our conversation. Are you available at 1030
> tomorrow?
>
> Haytham Faraj
> Sent from my iPhone
>
> On Mar 30, 2011, at 5:21 PM, "White Capt Bret A" <bret.a.white@usmc.mil>
> wrote:
>
>> Mr. Faraj,
>>
>> My contact numbers are below. My direct line will change after this
> Friday. I'll wait to hear from you regarding the nature of your engagement
> with SSgt Lopez and we can discuss the case fully at that time.
>>
>> Respectfully,
>>
>> 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: 703.784.4628/4615
>> Direct: 703.784.4635
>> Fax: 703.784.0259
>>
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>>
>>
>
>