RE: Witness Production Conversation of 20100827 (U.S. v. SSgt Wuterich) AND Requested concurrence for delay

[Haytham Faraj <haytham@puckettfaraj.com>]

Gentlemen,

I agree that Stafford doesn't need to be produced.  I will have to get back
to you later today or tomorrow on Briones and Dawson.

On another matter, I am going to file a motion today to request a one week
delay to the start of the trial.  It's actually more like a 4 day delay
since we won't be starting until the 15th.  I am writing to request you
concurrence to delay the start until September 20.  We would still go on the
record on the 13th to litigate pretrial motions and other matters.  We,
however, need the extra couple of days to continue to prepare.  Maj Meredith
had to go TAD this week to the east coast to work another case.  We
requested that our former legal clerk be assigned TAD to assist us and that
has yet to happen.  Please let me know your decision as soon as possible.

Vr,

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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-----Original Message-----
From: Brower Capt Matthew R [mailto:matthew.r.brower@usmc.mil] 
Sent: Tuesday, August 31, 2010 9:04 PM
To: Haytham; neal@puckettfaraj.com; cvokey@fhsulaw.com; Marshall Maj
Meridith L
Cc: Sullivan LtCol Sean; Gannon Maj Nicholas L
Subject: RE: Witness Production Conversation of 20100827 (U.S. v. SSgt
Wuterich)

Gentlemen and Ma'am,
     During a separate conversation also held on 27 August between Mr. Faraj
and Major Gannon it was further communicated to Major Gannon that the
defense would not be requesting Sgt Robert Stafford.  Please confirm that
this is indeed the defense's position.  

Additionally, we have to date been unable to contact Mr. Roel Briones.  We
are continuing to try to locate this witness, but have been unable to
contact him so far.

Lastly, on 20 April 2010 the government approved and ordered produced 1stLt
Shanen Dawson from 3rdLAR stationed at 29 Palms, CA to testify as a defense
witness.  He is currently undergoing predeployment training at Mohave Viper
and is slated to deploy with the 3rdLAR Advanced Party shortly after our
trial.  Please let me know if the defense is still requesting he be
produced.  If not, he will be able to avoid canceling his predeployment
leave which is currently scheduled to take place during the course of this
court martial.

Very Respectfully,

Matthew Brower
Captain, U.S. Marine Corps

-----Original Message-----
From: Brower Capt Matthew R 
Sent: Saturday, August 28, 2010 16:48
To: 'Haytham'
Subject: RE: Witness Production Conversation of 20100827 (U.S. v. SSgt
Wuterich)

Thanks Sir.

V/R

Capt Brower 

-----Original Message-----
From: Haytham [mailto:haytham@puckettfaraj.com]
Sent: Saturday, August 28, 2010 15:32
To: Brower Capt Matthew R
Cc: <neal@puckettfaraj.com>; <cvokey@fhsulaw.com>; Marshall Maj Meridith L;
Gannon Maj Nicholas L; Sullivan LtCol Sean
Subject: Re: Witness Production Conversation of 20100827 (U.S. v. SSgt
Wuterich)

Capt Brower,
Correct on all except SSgt   We do want him. I misspoke when I listed him as
a not needed. We do in fact want him. 

Haytham Faraj
760-521-7934
Sent from my iPhone

On Aug 27, 2010, at 5:41 PM, "Brower Capt Matthew R"
<matthew.r.brower@usmc.mil> wrote:

> Gentlemen, and Ma'am,
>     This e-mail is being sent to memorialize that Mr. Haytham and Major
Gannon in the presence of Mr. Vokey and myself had a conversation about the
following witnesses whom Mr. Haytham stated the defense would no longer be
requesting at the trial in this case:
> 
> -Rene Rodriguez
> 
> -Brian D. Whitt
> 
> -Martha Ann Noonan
> 
> -Jerrett Bilski
> 
> -Major Dana Haytt
> 
> -MSgt Dunlap
> 
> -SSgt Laughner
> 
> -LCol Jeffrey Chessani
> 
> -Neller
> 
> Please let me know if any of this information is incorrect or if there was
a misunderstanding on anyone's part about the defense no longer requesting
these witnesses.  Thanks.
> 
> Very Respectfully,
> 
> Matthew Brower
> Captain, USMC