| Patrick, Para 2: 1. Deleted "civilians, and family members" because there is no evidence of an intent to do that and there was no intent. Client not provident to that language. 2. Full paragraph beginning: "On 17 Jun 2009," delete the word, "incredibly." Not part of the science associated with the testing. Argument which you can make but not for a stip of fact. 3. Full paragraph beginning: "During the MP investigation" Delete sentences, "The Accused did not return . . .; The chain of command . . .; Members of the Accused's . . ." This simply did not happen. He was gone for the remainder of the day and returned and reported early the next morning. The command put him on restriction or conditions on liberty for the remainder of this period. You have counseling statements in the discovery for several of those days, counseling him for being late to report to sign in muster. He was gone for part of that first day but returned early the next morning. Para 3a: Delete "civilian, or dependent" See above Para 3b: First paragraph modified regarding assignment to missions. He was never assigned to missions during this time. Subjective assessment about weekend to weekday habit can be argued if required. Substituted language is accurate. Plus, the word "embellished" may not be the correct use of that word, so I changed the language, retaining the aggravating circumstance of the nature and sensitivity of the mission of The Old Guard, which no one denies. Para 3c: Same as 3b Para 3d: Same as 3b Para 3f: 1. See Para 2, subpara 3 above. Same change. He was not AWOL for 10 days. It's in the discovery. 2. End of 1st para, deleted "civilians, and dependents," see Para 2, subpara 1, above. Para 3j: Deleted "civilians, and military dependents" Para 3k: Deleted "civilian, or dependents" Those are all the changes I could find. Look forward to hearing back from you. V/r, Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC Washington DC | Virginia 888.970.0005 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |