RE: 3d UCI motion

[Haytham Faraj <haytham@puckettfaraj.com>]

We sent at this same time.  I just sent what I have completed.  I excised
several paragraphs.  RCM 1106 only applies to post trial. RCM 406 applies to
pretrial advice.  Also the case you cited wasn't on point.   I deleted
references to it and added another.

-----Original Message-----
From: Hur Capt Christian P [mailto:christian.hur@usmc.mil] 
Sent: Monday, November 01, 2010 10:14 AM
To: Haytham Faraj
Subject: RE: 3d UCI motion

Corrections made for grammar and pin cite.

Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 12, 1st Floor, MCRD, San Diego, CA 92140

This email may contain Attorney Work Product.  Please delete if you received
this message in error.
  


-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Thursday, October 28, 2010 12:29
To: Hur Capt Christian P
Subject: 3d UCI motion

Chris,

It took me a long time to get through this motion.  It?s almost complete
except for the portion highlighted in  yellow.  It requires some on point
case law.  The issues is disqualification of the SJA because she was
conflicted out.  If there?s no case law on point then just rely on the rule.
Otherwise it?s ready to go.  Please send it to me for one final check before
you file.

 

Haytham Faraj, Esq.

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