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RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER



Attached

-----Original Message-----
From: Hatch MAJ Douglas C [mailto:douglas.hatch@usmc.mil] 
Sent: Monday, April 26, 2010 8:28 PM
To: Sayegh LtCol Michael E; Day Capt Evan S; sean.sullivan@cox.net
Cc: Hur Capt Christian P; Haytham@puckettfaraj.com
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Sir,

Government counsel did not receive the defense comments.  Request that the
comments be forwarded to us, as otherwise they are ex parte communications.

V/R

Maj Hatch 

-----Original Message-----
From: Sayegh LtCol Michael E 
Sent: Monday, April 26, 2010 17:12
To: Day Capt Evan S; Hatch MAJ Douglas C; 'sean.sullivan@cox.net'
Cc: Hur Capt Christian P; 'Haytham@puckettfaraj.com'
Subject: Re: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Yes.  Rec. Before yours. 
LtCol Sayegh --------------------------
Sent from my BlackBerry Wireless Handheld


----- Original Message -----
From: Day Capt Evan S
To: Sayegh LtCol Michael E; Hatch MAJ Douglas C; 'sean.sullivan@cox.net'
<sean.sullivan@cox.net>
Cc: Hur Capt Christian P; 'Haytham Faraj' <Haytham@puckettfaraj.com>
Sent: Mon Apr 26 14:16:06 2010
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Gentlemen,

Was there a written argument submitted by the defense?

V/R,
Capt Day 

-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Friday, April 23, 2010 17:23
To: Hatch MAJ Douglas C; 'sean.sullivan@cox.net'
Cc: Hur Capt Christian P; 'Haytham Faraj'; Day Capt Evan S
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

received.  thanks all. 

-----Original Message-----
From: Hatch MAJ Douglas C
Sent: Friday, April 23, 2010 17:17
To: sean.sullivan@cox.net; Sayegh LtCol Michael E
Cc: Hur Capt Christian P; Haytham Faraj; Day Capt Evan S
Subject: RE: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Sir,

Attached are the government comments.  My apologies for the late submission.

FedEx address is:

Joint Law Center
Building 2244 Elrod Ave
San Diego, CA 92145

V/R

Maj Hatch 

-----Original Message-----
From: sean.sullivan@cox.net [mailto:sean.sullivan@cox.net]
Sent: Friday, April 23, 2010 17:07
To: Hatch MAJ Douglas C; Sayegh LtCol Michael E
Cc: Hur Capt Christian P; Haytham Faraj; Day Capt Evan S
Subject: Fw: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Sir
Maj Hatch is scanning government argument as we speak and will email to you
immediately

Sf. Ltcol Sullivan

Sent from my BlackBerryR smartphone with SprintSpeed

-----Original Message-----
From: "Sullivan LtCol Sean" <sean.sullivan@usmc.mil>
Date: Fri, 23 Apr 2010 16:40:09
To: <sean.sullivan@cox.net>
Subject: FW: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

It is 16:35 and I have yet to receive anything from either side.  Nothing
negative will come from not submitting comments or objections to the IO, but
if not received within the hour, nothing beyond what was argued at the
hearing will be considered.

LtCol Sayegh 

-----Original Message-----
From: sean.sullivan@cox.net [mailto:sean.sullivan@cox.net]
Sent: Thursday, April 22, 2010 9:50
To: Sayegh LtCol Michael E; Day Capt Evan S; Hur Capt Christian P; Haytham
Faraj
Subject: Re: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Rgr sir

Vrs. Ltcol Sullivan
Sent from my BlackBerryR smartphone with SprintSpeed

-----Original Message-----
From: "Sullivan LtCol Sean" <sean.sullivan@usmc.mil>
Date: Thu, 22 Apr 2010 09:24:51
To: <sean.sullivan@cox.net>
Subject: FW: FINAL COMMENTS AND OBJECTIONS DUE TOMORROW COB ICO WACKER

Gents:

Just a reminder these are due to me COB tomorrow.  Please note I will be TAD
all of next week but I will take what you submit with me.  My intent is to
have my report done by COB 5 May - a week from this Wed.  I will launch an
electronic version of the report and mail the entire thing via fedex to
Miramar Law Center.  Just need their FedEx address.

thanks.

LtCol Sayegh 

-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 14:07
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S;
Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Sir,

We will add any analysis of those notes to our argument due on Friday Sir.
There were no major discrepancies noted by the defense between the hand
written notes and the summaries of interviews.

Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego,
CA 92140

This email may contain Attorney Work Product.  Please delete if you received
this message in error. 
 
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 13:59
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S;
Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Gentlemen:

This is a 161 pages.  Is the defense submitting that I need to read this or
do they summarize their points adequately in their summations of the ROIs
previously submitted?  Alternatively, does the Government object if the
defense submits an alternate exhibit - (61) - where they summarize what they
feel is important for me to consider from what they read in the notes?

If either side prefers I read this in its entirety - I will.

s/f

LtCol Sayegh   

-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 13:38
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S;
Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Sir,

I believe the attached contains most if not all of the notes. 


Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego,
CA 92140

This email may contain Attorney Work Product.  Please delete if you received
this message in error. 
 
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 13:36
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S;
Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Can someone send those to me please? 

-----Original Message-----
From: Hur Capt Christian P
Sent: Monday, April 19, 2010 11:44
To: Sayegh LtCol Michael E; 'haytham@puckettfaraj.com'; Day Capt Evan S;
Sullivan LtCol Sean
Cc: 'farajh@gmail.com'
Subject: RE: IE NUMBER 61 ICO CAPTAIN WACKER

Sir,

61 was the handwritten notes of the NCIS agent that the defense received via
email from the trial counsel. 


Christian P. Hur
Captain, USMC
Senior Defense Counsel
Telephone:  (619) 524-8713
Fax:  (619) 524-6784
Address:  Defense Section, Bldg 7W, 2nd Floor, Parade Deck, MCRD, San Diego,
CA 92140

This email may contain Attorney Work Product.  Please delete if you received
this message in error. 
 
-----Original Message-----
From: Sayegh LtCol Michael E
Sent: Monday, April 19, 2010 11:02
To: Hur Capt Christian P; 'haytham@puckettfaraj.com'; Day Capt Evan S;
Sullivan LtCol Sean
Subject: IE NUMBER 61 ICO CAPTAIN WACKER

Gents:

In gathering the IEs, I could not find an IE 61.  I have IE 60 as the email
from Lovette Robinson and then pick up with the statements of Cook and
Barker as 62 and 63 respectively.  Please confirm that is an admin oversight
as opposed to me not having something.

thanks.

s/f

LtCol Sayegh 

 


Attachment: defense summation 32.pdf
Description: Adobe PDF document