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Re: Follow-up to CA's Counter to PTA



I think we're going to trial. Let's chat later this week about out trial prep. 

Haytham Faraj 
760-521-7934
Sent from my iPhone

On Oct 12, 2010, at 10:21 AM, "Gough, Charles C LTJG NLSO NC DET, GREAT LAKES"<charles.c.gough@navy.mil> wrote:

> Mr. Faraj,
> Any updates other than the emails on Wofford? Do you think they will come back and accept deal without the larceny? 
> V/R,
> LTJG Gough
> 
> -----Original Message-----
> From: Pennix, Elisabeth H LT RLSO MW 
> Sent: Monday, October 04, 2010 16:52
> To: 'Haytham Faraj'
> Cc: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES
> Subject: Follow-up to CA's Counter to PTA
> 
> Mr. Faraj, 
> 
> I know LT Gough is on leave right now but in the meantime, the CA has a counter-offer. He will accept her current offer with a modification - on the condition that she admit more about the larceny. The CA would be happy with her admitting to either a substituted dollar amount for the items that were not really purchased in Japan (the statement associated with her return of items without a receipt) or a substituted item listing. Any accountability or even pleading to an "attempt" charge concerning larceny would be acceptable. Please let me know what your client thinks of that plan.
> 
> The facts according to Mr. Soria and Mr. Watts substantiate that she indeed did return items, some of which were from the Exchange, but were not from Japan and were not sold in the past 45 days as is required by the return policy (when made without a receipt). It was her "false" statements that compelled the customer service worker to issue her returns on her items. 
> 
> Please just let me know. Also, if we go to trial, will you be making a motion to move the trial dates? I heard that at some point but haven't heard anything since. I am starting to talk to chains-of-command about witness travel and must know in advance, if you please.
> 
> Thank you and have a good day!
> 
> Sincerely,
> Lis
> 
> 
> LT Elisabeth H. Pennix, JAGC, USN
> Senior Trial Counsel
> Region Legal Service Office, Midwest
> 2540 Paul Jones Street
> Bldg. 2, Suite 300
> Great Lakes, IL 60088
> PH: (847) 688-3805, DSN: 792,3805
> FX: (847) 688-2481
> elisabeth.pennix@navy.mil
> 
>