Gentlemen,
I'm going to be out of the office all next week (I won't have access
to my NMCI computer files until the afternoon of 3 May). I'll receive
gmails via my smartphone however.
I know that Haytham had wanted me to create a supplemental UCI motion
fact section based on our last site visit. I also know that Maj
Scarselli had asked me to do a draft of the motion to dismiss for
failure of the Government to have evidence to support its charges.
To meet these two end-states, I've attached an early draft of this
motion (that also contains the UCI fact supplements). In this motion,
I attempt to attack the Government's charges that we know they no
longer have any evidence to support: false official statement charges
based on excluded statements, the GySgt Buchanan charges, etc.
I propose (if acceptable with you two) that Maj Scarselli first edit
the attached draft with facts and then send it back to me along with a
scanned copy of the charge sheet (if he has it). I don't have the
charge sheet on my home computer, which is why the attached needs much
editing. I'll then finish up the edits once I get Maj Scarselli's
version back and then send to Haytham for finalization and filing.
Please let me know if either of you want to do something else. I'm
tracking for 17 May as the date of the 2nd Motion's hearing (which
means we probably need to file the attached NLT first week of May).
Thanks.
On Fri, Mar 26, 2010 at 12:30 PM, Scarselli Maj Pietro P
<pietro.scarselli@usmc.mil> wrote:
Christian, please review soonest and let me know of any further
changes, if any...or if I should print, sign, scan and email back.
Please note significant changes.
Standing by....
Thanks. S/F! R/Maj Scarselli
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--
Christian P. Hur
<Scarselli Motion to dismiss failure of evidence.doc>