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RE: Notice of Representation by CDC--US v. CPT Hill



Unless, of course, you're calling the 8th the first full week. In that case, the answer is just yes.
Neal A. Puckett, Esq.
LtCol, USMC (Ret)
The Law Firm of Puckett & Faraj, PC
Washington DC - San Diego CA
www.puckettfaraj.com
888.970.0005


Quoting neal@puckettfaraj.com:

That's the first full week I'm available, not accounting for travel
time.  Later in that week or the first of the following week would
allow for travel and witness interview time after arrival.
I'll have that cover letter for the leave request back to you as soon
as I can today.
Neal A. Puckett, Esq.
LtCol, USMC (Ret)
The Law Firm of Puckett & Faraj, PC
Washington DC - San Diego CA
www.puckettfaraj.com
888.970.0005


Quoting "Masten, Heather A LTC USA TF WARRIOR"
<heather.masten@afghan.swa.army.mil>:

Just so I am certain, would the first week of December work for you?

-----Original Message-----
From: Neal Puckett [mailto:neal@puckettfaraj.com]
Sent: Monday, October 20, 2008 11:03 PM
To: Masten, Heather A LTC USA TF WARRIOR
Subject: Re: Notice of Representation by CDC--US v. CPT Hill

Not available in Nov until after Thanksgiving due to rape GCM at Camp
pendleton week of 17 Nov. Will last all week. Planning to travel there
on 10 Nov. for pretrial prep. In FL on business 4-8 Nov.  In Montgomery,
AL 31Oct-1Nov.

N. A. Puckett
LtCol, USMC (Ret)
Puckett & Faraj, PC

On Oct 20, 2008, at 8:06, "Masten, Heather A LTC USA TF WARRIOR"
<heather.masten@afghan.swa.army.mil
> wrote:

Thanks.  If you let me know when you are available in November, I can
draft the Art 32 delay request as well.  I am almost thinking the
first week of Dec (Dec 1st), given the holidays (for you, at least),
etc.

Have they sent you any information re: country clearance yet?

-----Original Message-----
From: Neal Puckett [mailto:neal@puckettfaraj.com]
Sent: Monday, October 20, 2008 7:05 PM
To: Masten, Heather A LTC USA TF WARRIOR
Subject: Re: Notice of Representation by CDC--US v. CPT Hill

Absolutely!

Neal A. Puckett, Esq
LtCol, USMC (Ret)
Puckett & Faraj, PC
Washington DC | San Diego
888.970.0005


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On Oct 20, 2008, at 10:25 AM, Masten, Heather A LTC USA TF WARRIOR
wrote:


  Thanks, Neal.  If possible, could you put this on your letterhead
and
  for your signature?  I have no problems doing the writing, but I
don't
  think I will have the impact that you will... Sad to say, but true.

  -----Original Message-----
  From: Neal Puckett [mailto:neal@puckettfaraj.com]
  Sent: Monday, October 20, 2008 6:40 PM
  To: Masten, Heather A LTC USA TF WARRIOR
  Subject: Re: Notice of Representation by CDC--US v. CPT Hill

  Agree with your analysis. Let's press with getting him leave.
Have trial
  prep today with court beginning tomorrow. I trust your instincts.
You
  have full authority to speak and write on my/our behalf.
  Neal

  N. A. Puckett
  LtCol, USMC (Ret)
  Puckett & Faraj, PC

  On Oct 20, 2008, at 2:24, "Masten, Heather A LTC USA TF WARRIOR"
  <heather.masten@afghan.swa.army.mil


      wrote:



      Thought I'd draft a rough cover letter for you if you are so
inclined


      to push this issue.





      -----Original Message-----


      From: Masten, Heather A LTC USA TF WARRIOR


      Sent: Monday, October 20, 2008 1:16 PM


      To: 'neal@puckettfaraj.com'


      Cc: Masten, Heather A LTC USA TF WARRIOR


      Subject: FW: Notice of Representation by CDC--US v. CPT Hill



      Neal,



      I'm not sure I'd let this go...but will follow your
lead.  I was


      thinking that we'd have CPT Hill submit a formal leave
request.  The


      evidence of a denial would help with sentencing--and
would also


      support a possible 6th Amendment motion.  The military
frequently


      forgets that Soldiers cannot adequately exercise their
right to


      counsel from a deployed environment.



      CPT Hill is facing life plus thirteen years.  15 days of
R&R,


      especially in light of his several enemy contacts, seems
a minimal


      action on the part of the command.  He's not a flight
risk, and he's


      not assigned any normal--or even necessary--duties.



      Again, I will follow your lead.  I'll have Roger fill
out a DA Form 31



      (leave request) and only have him submit it upon your
direction.



      HM



      -----Original Message-----


      From: Mullins, Jeffrey MAJ USA CTF Currahee SJA OIC


      Sent: Monday, October 20, 2008 11:09 AM


      To: Masten, Heather A LTC USA TF WARRIOR


      Cc: 'neal@puckettfaraj.com'; Johnson, Henry Q USA MAJ
USA CJTF101 JOC;



      Latino, Stephen E CPT USA CTF Currahee JAG


      Subject: RE: Notice of Representation by CDC--US v. CPT
Hill



      LTC Masten,



      CPT Hill's chain of command does not believe that this
is a good time


      for CPT Hill to take R&R given the current attempts to
schedule an


      Art.


      32 hearing and the uncertainty with the date of the Art.
32 Hearing.



      It is also my understanding that CPT Hill's chain of
command will have



      him return to FOB Salerno within a day or two.



      v/r



      JEFFREY J. MULLINS


      Command Judge Advocate


      Combined Task Force Currahee


      DSN: 318-851-0076


      SVOIP: 851-1034


      Mobile: 0707-435-084



      -----Original Message-----


      From: Masten, Heather A LTC USA TF WARRIOR


      Sent: Sunday, October 19, 2008 5:46 PM


      To: Johnson, Henry Q USA MAJ USA CJTF101 JOC; Mullins,
Jeffrey MAJ USA



      CTF Currahee SJA OIC; Latino, Stephen E CPT USA CTF
Currahee JAG


      Cc: Masten, Heather A LTC USA TF WARRIOR;
neal@puckettfaraj.com


      Subject: Notice of Representation by CDC--US v. CPT Hill



      ALCON,



      Please see attached notice re: the CDC in this case.
Also, we need to



      start the country clearance and security clearance
procedures ASAP.



      Finally, I am trying to ascertain the ability of having
CPT Hill take


      his R&R soon.  I am traveling to Charlottesville and
have set up a


      meeting with Mr. Puckett.  Obviously, having a client
present during


      these discussions is helpful, if not necessary.  Please
advise.  My


      travel dates in the Washington DC area to meet with Mr.
Puckett are


      tentatively scheduled to occur o/a 2 or 3 November.  As
a side note,


      CPT Hill has been in theater more since at least April
2008 and


      encountered numerous enemy contacts while at FOB
Airborne.  Added to


      that, he has had the added stress of this case.



      v/r





      HEATHER A. MASTEN


      LTC, JA


      Senior Defense Counsel


      U.S. Army Trial Defense Service


      Afghanistan Field Office


      Bagram AB, Afghanistan


      DSN: 318-431-4323


      heather.masten@afghan.swa.army.mil



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      <Draft Leave Request Cover Letter.doc>