| Patrick, I think arraignment on 11 March 2010 is not necessary since we're not pressing for a speedy trial and we've both agreed to a date. I'll be in an Art 32 on the 11th at Camp Lejeune, NC. I will state in this email that we do not intend to bring a motion to dismiss for lack of a speedy trial, agree to 7 April as the hearing date and agree that any delay beyond when the government could have arraigned PFC Will, specifically 11 March 2010 and 7 April 2010, is excludable delay for speedy trial purposes (RCM 707) due to unavailability of civilian defense counsel. The contents of this email can be made an appellate exhibit if you wish. 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. On Mar 2, 2010, at 12:58 PM, Cashman, Patrick J. CPT USA JFHQ-NCR/MDW SJA wrote: Classification: UNCLASSIFIED Caveats: FOUO Sir, That works. Also wanted to ask, would you be opposed to doing the Arraignment on 11 March right before the contested court-martial that is being held here at Fort McNair. The only reason why is because Will is in PTC and I know that the military judges are sensitive to that. So at the end of the day we would do the arraignment on 11 March and then do the actual guilty plea on 7 April 2010. Please let me know if you are o.k. with that or if you feel that that is not necessary and we should just do the arraignment and guilty plea session all on the 7th. Thanks again. V/R, CPT Cashman |