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RE: Brito UCI motion



I think this motion is better styled as an Article 13 motion. You and I have
been infected with the "handy hammer" syndrome, meaning with a handy hammer
in our hand we're starting to see everything as a nail.  We're starting to
see ever issue as UCI.  This is illegal pretrial punishment.  I don't think
there's UCI here.

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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-----Original Message-----
From: Hur Capt Christian P [mailto:christian.hur@usmc.mil] 
Sent: Thursday, September 16, 2010 6:05 PM
To: Faraj, Haytham
Cc: BritoJL@yahoo.com
Subject: Brito UCI motion

Haytham,

As requested.  Its ready for your editing, signature and filing.  I've gone
over it with Sgt Brito several times now.  It's not the strongest UCI, but
there a few issues that will raise appellate review:  1.  It's weird how
many different times they moved this Marine, 2. They are denying him leave
as some sort of pretrial punishment and 3.  They are demeaning him regularly
in front of senior and junior Marines.  

All of it together means that he can't get a fair trail from 12th MCD.

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

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