RE: Motions ICO U.S. v. Wuterich

["Haytham Faraj" <haytham@puckettfaraj.com>]

Defense has no objection to your recommendation your honor.  

I would like to bring a matter to your attention and offer a suggestion.  I
submitted a witness request to the government to which they promptly
responded.  They denied some of the witnesses we requested.  I have been in
back to back hearings or trials the last 3 weeks.  Accordingly, I was not
able to submit a motion to compel witness production.  Over the next 2-3
weeks I will work with government counsel to provide additional
justification for why the witnesses should be produced.  In the event we
cannot come to a resolution I recommend doing what you have done in the
past: submit the dispute to you for resolution and decision in an 802 that
can be summarized the next time we get on the record. I am confident,
however, that we will reach an agreement on the witnesses.

Vrs,

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
WASHINGTON DC׀  SAN DIEGO ׀ DEARBORN
www.puckettfaraj.com
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-----Original Message-----
From: Jones LtCol David M [mailto:david.m.jones5@usmc.mil] 
Sent: Tuesday, April 27, 2010 4:17 AM
To: Gannon Maj Nicholas L
Cc: Haytham Faraj; Neal Puckett; Sullivan LtCol Sean
Subject: RE: Motions ICO U.S. v. Wuterich

All,

I have received no motions from the defense by 26 April, which was the
submission deadline.  Therefore, I understand there to be no issues
regarding experts, etc. that need to be decided early so as not to delay our
trial schedule.  Considering these two government motions do not appear to
be time sensitive, I recommend that we forgo the motions session in May and
plan to meet up 26-27 August to litigate these two government motions and
any further non time sensitive motions the defense may file.  I need to know
immediately if either side objects to this and if so, why.

R,

LtCol David M. Jones
Circuit Military Judge
Western Pacific Judicial Circuit
Navy-Marine Corps Trial Judiciary
Office: 645-7287 / 2156
Fax: 645-2035