RE: MCAS Miramar Docketing Request week of 27 Sept - 1 Oct

[Haytham Faraj <haytham@puckettfaraj.com>]

I'll be in town this afternoon.  If you like we can meet tonight.  We will
probably lose all our motions except some piece of the suppression motion. I
don't want you to stress.   A win in this case is beating 12 months.  This
is a sentencing case all the way.  That said, I agree that we need to get to
Fallon.  If we need a continuance then let's do that.  The client is not
harmed by a continuance because he continues to get paid.  Once he's
sentenced that stops.

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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-----Original Message-----
From: Crosswell Capt Ryan R [mailto:ryan.crosswell@usmc.mil] 
Sent: Wednesday, September 29, 2010 1:38 AM
To: Haytham Faraj
Cc: Marshall Maj Meridith L
Subject: FW: MCAS Miramar Docketing Request week of 27 Sept - 1 Oct

Sir, 

It just occurred to me that you may not have received this. Just wanted to
confirm that you're aware we're on for Friday. My clerk said that you're
going to be in town tomorrow and (I assume) Thursday. I think we really need
some "chalk talk" on Thursday to come up with a plan and a division of
labor. My concern is that I'm in a GCM the week before Wylde kicks, and the
trial is probably going to stretch into that Saturday. I'm also concerned
that if we lose the motion on the Government's provision of an investigator,
at least one of us will need to do a site visit to Fallon. But next week,
I'm in court or an AdSep Board on Monday, Tuesday and Wednesday, and I've
taken leave on Friday (to prepare for trial the next week).

See you later this week.

S/f,
Ryan

-----Original Message-----
From: Rubin LtCol Peter R 
Sent: Tuesday, September 21, 2010 16:55
To: Hatch MAJ Douglas C; Grisalesmery Cpl Alejandro
Cc: Douvas Capt Alex G; Day Capt Evan S; Leggett GySgt Terrance R; Crosswell
Capt Ryan R; Garrett LCpl Kathryn S; Marshall Maj Meridith L; Orellana SSgt
Luis M; Richardson Col Michael B; Logan Capt Gavin K
Subject: RE: MCAS Miramar Docketing Request week of 27 Sept - 1 Oct

Copy all.  Thanks for the email. R/LtCol Rubin 

-----Original Message-----
From: Hatch MAJ Douglas C 
Sent: Tuesday, September 21, 2010 4:01 PM
To: Rubin LtCol Peter R; Grisalesmery Cpl Alejandro
Cc: Douvas Capt Alex G; Day Capt Evan S; Leggett GySgt Terrance R; Crosswell
Capt Ryan R; Garrett LCpl Kathryn S; Marshall Maj Meridith L; Orellana SSgt
Luis M; Richardson Col Michael B; Logan Capt Gavin K
Subject: MCAS Miramar Docketing Request week of 27 Sept - 1 Oct

Good afternoon sir,

Per the attached, request to docket a 39(a) session (motions and final
rulings) in U.S. v. Roumer on 29 Sept and a 39(a) session in U.S. v. Wylde
(motions) on 1 Oct.  Request to hear the 39(a) ICO U.S. v. Wylde at the 32nd
St courtroom due to MCAS Miramar air show; full explanation will be provided
in PTIR's, to follow in separate emails.

Negative docketing request for the following cases:

U.S. v. Darrow had a 39(a) motions date scheduled for 29 September, but no
motions were filed in that case.

U.S. v. Wacker had 39(a) motions dates scheduled for 29 Sept-1 Oct, but all
dates have moved since LtCol Jones' assignment as MJ on that case.
Tentative new motions dates on Wacker are 25-28 Jan, trial tentatively set
for 7-18 Feb.

V/R

Major Doug Hatch, USMC
Military Justice Officer
3d Marine Air Wing & MCAS Miramar
(858)577-6859