Title: Volume FOIA 006

Release Date: 2014-03-20

Text: 01544



Volume 6 of 111
SJAR ROT
FOIA Version

VERBAT IM 1

RECORD OF TRIAL2

(and accompanying papers)















of
(Name: Last, First, Middie initiai) (Sociai Security Number) (Rank)
Headquarters and
Headquarters Company,
United States Army Garrison U-S- Army Fort Myer, VA 22211
(Unit/Command Name) (Branch of Service) (Station or Ship)
By
GENERAL COURT-MARTIAL
convened by Commander



(Titie of Con vening Authority)

UNITED STATES ARMY MILITARY DISTRICT OF WASHINGTON
(Unit/Command of Con vening Authority)

Tried at

Fort. Meade, MD on see below

(Piace or Piaces of Triai) (Date or Dates of Triai)







Date or Dates of Trial:

23 February 2012, 15?16 March 2012, 24?26 April 2012, 6?8 June 2012, 25 June 2012,

16?19 July 2012, 28?30 August 2012, 2 October 2012, 12 October 2012, 17?18 October 2012,
7?8 November 2012, 27 November 2 December 2012, 5?7 December 2012, 10?11 December 2012,
8?9 January 2013, 16 January 2013, 26 February 1 March 2013, 8 March 2013,

10 April 2013, 7?8 May 2013, 21 May 2013, 3?5 June 2013, 10?12 JUne 2013, l7?18 June 2013,
25?28 June 2013, 1?2 July 2013, 8?10 July 2013, 15 July 2013, 18?19 July 2013,

25?26 July 2013, 28 July 2 August 2013, 5?9 August 2013, 12?14 August 2013,

16 August 2013, and 19?21 August 2013.

1 insert "verbatim or "summarized as appropriate. This form be used by the Army and Navy for verbatim records of triai oniy.)

2 See inside back co ver for instructions as to preparation and arrangement.

DD FORM 490, MAY 2000 PREVIOUS EDITION IS OBSOLETE Front Cover



01545



From: USARMY (US)

To: in A MA ARMY MDW

Cc: David E. Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow JoDean
(Joe) CPT USARMY USAMDW USARMY USAMDW (US)

Subject: Request for additional funding request for (Nberagents Trent Struttmann (UNCLASSIFIED)

Date: Wednesday, June 19, 2013 12:16:44 PM

Attachments: Re uest for additional fundin re uest for bera ents nc..docx

Re uest for additional fundin re uest for bera ents df



Classification: UNCLASSIFIED
Caveats: NONE

Good Afternoon,

Attached is the request for additional Funding for the Defense computer forensics expert. Please advise the Defense
on any additional information needed. Thank you.



ssa?

Classification: UNCLASSIFIED
Caveats: NONE

Page 228 of 2169

01546

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW r Th FMA ARMY ;David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stips
Date: Wednesday, June 19, 2013 8:58:34 AM



Roger. SSG- will be over this morning to pick up the disc. We will have several of the first batch over to
you today for your review.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, June 18, 2013 5:31 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stips

Gents,
We finished the following stipulations:

Seche
Feeley
Mundy
anek
#23
#107
Murphy

Newewwr

Attached is Murphy. We have Seche, Feeley, Mundy, and anek on a classified CD ready for delivery. We sent #23
and #107 to their organization for review and should have back in a day or so. For Mundy and anek, we accepted
all the changes you made, and added a few edits based on their feedback.

We still do not have an answer on Wisecarver and Johnson, G. But for these two, we are not tracking any more
stipulations in our control. The defense has the rest and we are standing by for feedback.

v/r
MAJ Fein

Page 229 of 2169

01547

From: Fein, Ashden MAJ USARMY MDW (US)
To: Hurley, Thomas David mgmpe; TQQman, ,(gehue QPT (us)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY

USAMDW (US)
Bcc:
Subject: Stips
Date: Tuesday, June 18, 2013 5:30:00 PM

Attachments: 130618 of Expected Testimony



Gents,
We finished the following stipulations:

Seche
Feeley
Mundy
anek
#23
#107

. Murphy

eewewwr

Attached is Murphy. We have Seche, Feeley, Mundy, and anek on a classified CD ready for delivery. We sent #23
and #107 to their organization for review and should have back in a day or so. For Mundy and anek, we accepted
all the changes you made, and added a few edits based on their feedback.

We still do not have an answer on Wisecarver and Johnson, G. But for these two, we are not tracking any more
stipulations in our control. The defense has the rest and we are standing by for feedback.

V/r
MAJ Fein

Page 230 of 2169

01548

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW r Th FMA ARMY ;David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Update
Date: Monday, June 17, 2013 8:05:36 AM



Sir

What's the deal with Benthal? Have you all tracked him down?



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 17, 2013 7:40 AM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stip-Update

MAJ Hurley,

If 107 and 23 have stips, then 63 should no longer be needed. With Downey stip, Collins drops off. I was incorrect
with anek and Mundy. We are still waiting to hear back from them as of Friday.

Harward should be on its way shortly.

V/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 17, 2013 7:38 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stip-Update

MAJ Fein

1. You guys still calling #63?

2. Does a signed Downey stip mean that Collins falls off of the list?

3. We have anek and Mundy? The last thing we could find yesterday was us sending back corrections to you guys.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Page 231 of 2169

01549

Sent: Sunday, June 16, 2013 11:07 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Update

Gents,
Below is a summary of outstanding stips.

Johnson, - we owe an answer whether he would testify to the fact about express/implied
Wisecarver - same as Johnson,

Pearce - defense has

Seche - government finishing and defense should receive tomorrow
Yamamoto - defense has

Yun - defense has

Feeley - government finishing and defense should receive tomorrow
Moore - defense has

Yavonovitch - defense has

. Pittman - defense has

. Murphy - State is reviewing

. anek - defense has

. Mundy - defense has

. Downey - complete, needs to be signed

. Harward - government has to review

. #107 - we will amend and write #23 so they are not cumulative

. Bigelow - defense has

. Williamson - complete, needs to be signed

. Aboul-Enein - defense should receive tonight

. #23 - see #107 above



[\Jr?r?r?r?r?r?r?r?r?r?o


v/r
MAJ Fein

Page 232 of 2169

01550

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW Tooman, ,(gehue QPT USARMY David mgmpe
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Harward
Date: Monday, June 17, 2013 8:00:59 AM



MAJ Fein
Looks good. I will have the client review along with Downey and Williamson.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 17, 2013 11:53 AM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stip-Harward

MAJ Hurley,

Attached is the updated Harward Stipulation. We accepted all changes. Deleted the habeas mil-com ligitation and
made a few edits. Our proposal this morning is to have Motes and Woods laid out for you and PFC Manning to go
through before 0930. Once we start, the MJ goes through the colloquy for those two. Then we recess, lay out the
remaining ones we have executed with the evidence. Come back on and then she goes through the colloquy for the
remainder, and we continue.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 17, 2013 7:34 AM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)
Subject: RE: Stip-Harward

All

We won't need the last two sentences in the open source info (about habeas and mil-comm litigation). Sorry for any
confusion.

Page 233 of 2169

01551

My bad.

Tom



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 9:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Harward

Harward comments attached. Apologies if you got this already, but I received an error message.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:07 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Harward

Gents,
Harward attached.

v/r
MAJ Fein

Page 234 of 2169

01552

From: Fein Ashden MAJ USARMY MDW (US)
To: Th FMA ARMY ;TQQman ,(gemta David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: Stip-AbouI-Enein
Date: Monday, June 17, 2013 7:59:00 AM
Attachments: 130617 of Exoected Testimony



Gents,
Aboul-Enein attached.

V/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 17, 2013 7:38 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stip-Update

MAJ Fein

1. You guys still calling #63?

2. Does a signed Downey stip mean that Collins falls off of the list?

3. We have anek and Mundy? The last thing we could find yesterday was us sending back corrections to you guys.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 11:07 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US) 6

Subject: Stip-Update

Gents,
Below is a summary of outstanding stips.
1. Johnson, - we owe an answer whether he would testify to the fact about express/implied

2. Wisecarver - same as Johnson,
3. Pearce - defense has

Page 235 of 2169



9.

10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.

v/r

Seche - government finishing and defense should receive tomorrow
Yamamoto - defense has

Yun - defense has

Feeley - government finishing and defense should receive tomorrow
Moore - defense has

Yavonovitch - defense has

Pittman - defense has

Murphy - State is reviewing

anek - defense has

Mundy - defense has

Downey - complete, needs to be signed

Harward - government has to review

#107 - we will amend and write #23 so they are not cumulative
Bigelow - defense has

Williamson - complete, needs to be signed

Aboul-Enein - defense should receive tonight

#23 - see #107 above

MAJ Fein

Page 236 of 2169

01553

01554

From: Fein, Ashden MAJ USARMY MDW (US)
To: Th FMA ARMY ;TQQman ,(gemte David
Cc: USARMY us Morrow JoDean Joe CPT USARMY USAMDW us Over aard An e

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: RE: Stip-Harward
Date: Monday, June 17, 2013 7:53:00 AM

Attachments: 130617 of Expected Testimony (HarwardR).docx



MAJ Hurley,

Attached is the updated Harward Stipulation. We accepted all changes. Deleted the habeas mil-com ligitation and
made a few edits. Our proposal this morning is to have Motes and Woods laid out for you and PFC Manning to go
through before 0930. Once we start, the MJ goes through the colloquy for those two. Then we recess, lay out the
remaining ones we have executed with the evidence. Come back on and then she goes through the colloquy for the
remainder, and we continue.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 17, 2013 7:34 AM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stip-Harward

All

We won't need the last two sentences in the open source info (about habeas and mil-comm litigation). Sorry for any
confusion.

My bad.

Tom



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 9:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
6

USARMY USAMDW (US)

Page 237 of 2169

01555

Subject: RE: Stip-Harward

Harward comments attached. Apologies if you got this already, but I received an error message.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:07 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Harward

Gents,
Harward attached.

V/r
MAJ Fein

Page 238 of 2169

01556

From: Fein, Ashden MAJ USARMY MDW (US)
To: Th FMA ARMY ;TQQman ,(gemte David
Cc: USARMY us Morrow JoDean Joe CPT USARMY USAMDW us Over aard An el

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Update
Date: Monday, June 17, 2013 7:40:00 AM



MAJ Hurley,

If 107 and 23 have stips, then 63 should no longer be needed. With Downey stip, Collins drops off. I was incorrect
with anek and Mundy. We are still waiting to hear back from them as of Friday.

Harward should be on its way shortly.

V/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 17, 2013 7:38 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stip-Update

MAJ Fein

1. You guys still calling #63?

2. Does a signed Downey stip mean that Collins falls off of the list?

3. We have anek and Mundy? The last thing we could find yesterday was us sending back corrections to you guys.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 11:07 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stip-Update

Gents,

Below is a summary of outstanding stips.

1. Johnson, - we owe an answer whether he would testify to the fact about express/implied
2. Wisecarver - same as Johnson,

Page 239 of 2169



9.

10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.

v/r

Pearce - defense has

Seche - government finishing and defense should receive tomorrow
Yamamoto - defense has

Yun - defense has

Feeley - government finishing and defense should receive tomorrow
Moore - defense has

Yavonovitch - defense has

Pittman - defense has

Murphy - State is reviewing

anek - defense has

Mundy - defense has

Downey - complete, needs to be signed

Harward - government has to review

#107 - we will amend and write #23 so they are not cumulative
Bigelow - defense has

Williamson - complete, needs to be signed

Aboul-Enein - defense should receive tonight

#23 - see #107 above

MAJ Fein

Page 240 of 2169

01557

01558

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW Tooman, ,(gehua QPT USARMY David mgmpe
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Update
Date: Monday, June 17, 2013 7:38:11 AM



MAJ Fein

1. You guys still calling #63?

2. Does a signed Downey stip mean that Collins falls off of the list?

3. We have anek and Mundy? The last thing we could find yesterday was us sending back corrections to you guys.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 11:07 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Update

Gents,
Below is a summary of outstanding stips.

Johnson, - we owe an answer whether he would testify to the fact about express/implied
Wisecarver - same as Johnson,

Pearce - defense has

Seche - government finishing and defense should receive tomorrow
Yamamoto - defense has

Yun - defense has

Feeley - government finishing and defense should receive tomorrow
Moore - defense has

Yavonovitch - defense has

. Pittman - defense has

. Murphy - State is reviewing

. anek - defense has

. Mundy - defense has

. Downey - complete, needs to be signed

. Harward - government has to review

. #107 - we will amend and write #23 so they are not cumulative

. Bigelow - defense has

. Williamson - complete, needs to be signed

. Aboul-Enein - defense should receive tonight

. #23 - see #107 above



[\Jr?r?r?r?r?r?r?r?r?r?o


v/r

Page 241 of 2169

01559

MAJ Fein

Page 242 of 2169

01560



From: Fein, Ashden MAJ USARMY MDW (US)
To: r Th MA ARMY
Subject: RE: chat

Date: Monday, June 17, 2013 7:34:00 AM
Sounds good.



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 17, 2013 7:28 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: chat

MAJ Fein

We can talk this morning before the 802. I just wanted to "level the bubbles" on all of the stipulations.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Monday, June 17, 2013 1:40 AM

To: Hurley, Thomas MAJ USARMY (US)
Subject: chat

MAJ Hurley- do you still want to chat tonight? I just saw that you asked for me to call. Thanks.

Page 243 of 2169

01561

From: Hurley, Thomas MAJ USARMY (US)
To: TQQman ,(gghua QPT USARMY in A MA ARMY MDW David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Harward
Date: Monday, June 17, 2013 7:33:59 AM



All

We won't need the last two sentences in the open source info (about habeas and mil-comm litigation). Sorry for any
confusion.

My bad.

Tom



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 9:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Harward

Harward comments attached. Apologies if you got this already, but I received an error message.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:07 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stip-Harward

Gents,
Harward attached.

v/r

Page 244 of 2169

01562

MAJ Fein

Page 245 of 2169

01563



From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW
Subject: RE: chat

Date: Monday, June 17, 2013 7:27:33 AM
MAJ Fein

We can talk this morning before the 802. I just wanted to "level the bubbles" on all of the stipulations.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Monday, June 17, 2013 1:40 AM

To: Hurley, Thomas MAJ USARMY (US)
Subject: chat

MAJ Hurley- do you still want to chat tonight? I just saw that you asked for me to call. Thanks.

Page 246 of 2169

01564

From: Fein, Ashden MAJ USARMY MDW (US)
To: r Th MA ARMY
Subject: chat

Date: Sunday, June 16, 2013 9:40:00 PM



MAJ Hurley- do you still want to chat tonight? I just saw that you asked for me to call. Thanks.

Page 247 of 2169

01565



From: Fein, Ashden MAJ USARMY MDW (US)

To: ngman, lJoshua ,1 QPT LJSARMY David r Th MA ARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)

Bcc:

Subject: Stip-Update

Date: Sunday, June 16, 2013 7:07:00 PM

Gents,

Below is a summary of outstanding stips.

p9?>199?WNf

HH
HO




v/r
MAJ Fein

Page 248 of 2169

Johnson, - we owe an answer whether he would testify to the fact about express/implied
Wisecarver - same as Johnson,

Pearce - defense has

Seche - government finishing and defense should receive tomorrow
Yamamoto - defense has

Yun - defense has

Feeley - government finishing and defense should receive tomorrow
Moore - defense has

Yavonovitch - defense has

. Pittman - defense has

. Murphy - State is reviewing

. anek - defense has

. Mundy - defense has

. Downey - complete, needs to be signed

. Harward - government has to review

. #107 - we will amend and write #23 so they are not cumulative

. Bigelow - defense has

. Williamson - complete, needs to be signed

. Aboul-Enein - defense should receive tonight

. #23 - see #107 above

From:
To:

Subject:
Date:
Attachments:

01566

Tooman, Joshua CPT USARMY (US)
Fain, MAJ USARMY MDW David (329mm; rl Th MA ARMY

USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)
RE: Stip-Harward
Sunday, June 16, 2013 5:50:49 PM

Harward Sti s.docx





Harward comments attached. Apologies if you got this already, but I received an error message.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 4:07 PM
To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc:

USARMY Morrow, oDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Harward

Gents,

Harward attached.

V/r
MAJ Fein

Page 249 of 2169

From:
To:

Subject:
Date:
Attachments:

01567

Tooman, Joshua CPT USARMY (US)
Fain, MAJ USARMY MDW David (329mm; rl Th MA ARMY

USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)
RE: Stip-Harward
Sunday, June 16, 2013 5:49:03 PM

Harward Sti s.docx





Harward comments attached.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 4:07 PM
To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc:

USARMY Morrow, oDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Harward

Gents,

Harward attached.

V/r
MAJ Fein

Page 250 of 2169

01568

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW ;David mgmhe; Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Williamson
Date: Sunday, June 16, 2013 5:35:55 PM



Roger.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 5:33 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Josh,

No issues with the sitp. Please accept all changes for tomorrow. PE 11 is DN 73-10, Item 1, which is already
admitted and contains the forensic image of the Bigelow computer. The other PE for ID will be filled in
tomorrow when we conduct the layout for PFC Manning to review.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 5:31 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US) 6

Subject: RE: Stip-Williamson

Tweaked #15. See attached. Noticed that you all added some PE but not others. Was that intentional?



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 5:26 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Page 251 of2169

01569

Gents,
Williamson attached. We accepted all your changes and made a few edits.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 4:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Williamson with our comments.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs; Hurley,
Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Gents,

If there are no issues with Williamson, please don't sign yet. We are going to send a different version shortly, that
includes the for the actual evidence and other identifying information.

Thank you.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:01 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Williamson

Gents,
Williamson attached.



Page 252 of 2169

01570

From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips- Bigelow

Sir,
Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stips- Bigelow

Gents,
Attached is the Bigelow Stip.

V/r
Ashden

Page 253 of 2169

01571

From: Fein Ashden MAJ USARMY MDW (US)
To: TQQman ,(ggmta David Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: RE: Stip-Williamson
Date: Sunday, June 16, 2013 5:33:00 PM



Josh,

No issues with the sitp. Please accept all changes for tomorrow. PE 11 is DN 73-10, Item 1, which is already
admitted and contains the forensic image of the Bigelow computer. The other PE for ID will be filled in
tomorrow when we conduct the layout for PFC Manning to review.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 5:31 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Tweaked #15. See attached. Noticed that you all added some PE but not others. Was that intentional?



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 5:26 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Gents,

Williamson attached. We accepted all your changes and made a few edits.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 4:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW

Page 254 of 2169

01572

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Williamson with our comments.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs; Hurley,
Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Gents,

If there are no issues with Williamson, please don't sign yet. We are going to send a different version shortly, that
includes the for the actual evidence and other identifying information.

Thank you.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:01 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Williamson

Gents,
Williamson attached.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips- Bigelow

Sir,

Page 255 of 2169

01573

Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stips- Bigelow

Gents,
Attached is the Bigelow Stip.

V/r
Ashden

Page 256 of 2169

01574

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW ;David rl Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Williamson
Date: Sunday, June 16, 2013 5:31:25 PM
Attachments: Williamson Stigdocx



Tweaked #15. See attached. Noticed that you all added some PE but not others. Was that intentional?



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 5:26 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Gents,
Williamson attached. We accepted all your changes and made a few edits.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 4:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Williamson with our comments.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs; Hurley,
Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Page 257 of 2169

01575

Gents,

If there are no issues with Williamson, please don't sign yet. We are going to send a different version shortly, that
includes the for the actual evidence and other identifying information.

Thank you.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:01 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Williamson

Gents,
Williamson attached.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips- Bigelow

Sir,
Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Page 258 of 2169

01576

Subject: Stips- Bigelow

Gents,

Attached is the Bigelow Stip.

V/r
Ashden

Page 259 of 2169

01577

From: Fein Ashden MAJ USARMY MDW (US)
To: TQQman ,(gemta David Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: RE: Stip-Williamson
Date: Sunday, June 16, 2013 5:26:00 PM
Attachments: 130616 of Exgected Testimony (WilliamsonA).docx



Gents,
Williamson attached. We accepted all your changes and made a few edits.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 4:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Williamson with our comments.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs; Hurley,
Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Gents,

If there are no issues with Williamson, please don't sign yet. We are going to send a different version shortly, that
includes the for the actual evidence and other identifying information.

Thank you.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 4:01 PM

Page 260 of 2169

01578

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US) 6

Subject: Stip-Williamson

Gents,
Williamson attached.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips- Bigelow

Sir,
Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stips- Bigelow

Gents,
Attached is the Bigelow Stip.

v/r
Ashden

Page 261 of 2169

From:
To:

Subject:
Date:

01579

Tooman, Joshua CPT USARMY (US)
in A MA ARMY MDW David mombs; r Th MA ARMY

USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)
RE: Stip-Downey
Sunday, June 16, 2013 5:10:46 PM





Downey is good to go. We'll print and have the client sign tomorrow.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 4:12 PM
To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc:

USARMY Morrow, oDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Downey

Gents,

Downey attached.

V/r
MAJ Fein

Page 262 of 2169

01580

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman ,(ggmta David Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Williamson
Date: Sunday, June 16. 2013 4:54:00 PM



Gents,
Thanks. We are verifying and should have out the door in the next 10-15 minutes.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 4:50 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Williamson with our comments.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs; Hurley,
Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Gents,

If there are no issues with Williamson, please don't sign yet. We are going to send a different version shortly, that
includes the for the actual evidence and other identifying information.

Thank you.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:01 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW

Page 263 of 2169

01581

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stip-Williamson
Gents,
Williamson attached.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips- Bigelow

Sir,
Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US) 6

Subject: Stips- Bigelow

Gents,
Attached is the Bigelow Stip.

V/r
Ashden

Page 264 of 2169

01582

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW ;David mgmha; rl Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stip-Williamson
Date: Sunday, June 16, 2013 4:50:16 PM
Attachments: Williamson Stigdocx



Williamson with our comments.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs; Hurley,
Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stip-Williamson

Gents,

If there are no issues with Williamson, please don't sign yet. We are going to send a different version shortly, that
includes the for the actual evidence and other identifying information.

Thank you.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:01 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Williamson

Gents,
Williamson attached.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY (USE

Page 265 of 2169

01583

USARMY USAMDW (US)
Subject: RE: Stips- Bigelow

Sir,

Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stips- Bigelow

Gents,
Attached is the Bigelow Stip.

V/r
Ashden

Page 266 of 2169

01584

From: Fein Ashden MAJ USARMY MDW (US)

To: in A MA ARMY MDW TQQman ,(ggmta QPT USARMY David Hurley Thomas
USARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY

USAMDW (US)
Bcc:
Subject: RE: Stip-Williamson
Date: Sunday, June 16, 2013 4:43:00 PM



Gents,

If there are no issues with Williamson, please don't sign yet. We are going to send a different version shortly, that
includes the for the actual evidence and other identifying information.

Thank you.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 4:01 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stip-Williamson

Gents,

Williamson attached.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US) 6

Subject: RE: Stips- Bigelow

Sir,
Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman

Page 267 of 2169

01585



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stips- Bigelow

Gents,
Attached is the Bigelow Stip.

V/r
Ashden

Page 268 of 2169

01586



From: Tooman, Joshua CPT USARMY (US)

To: An PT ARMY r Th FMA ARMY

Cc: Fein, Ashden MAJ USARMY MDW David E. Coombs; Morrow, JoDean (Joe) CPT USARMY USAMDW (US)
Subject: RE: Stips (UNCLASSIFIED)

Date: Sunday, June 16, 2013 4:39:06 PM

Angel

MAJ agrees with you that things could be wrapped up into 107 or we could supplement with short stips on 23 or
63. No preference here.

V/r

Josh



From: Overgaard, Angel CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW David E. Coombs; Tooman, Joshua CPT USARMY
Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Subject: Stips (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Sir,

I think that you have a point about 107, 23, and 63. There are a few things that are missing, but we could probably
either wrap it all up in the 107 stip or do a quick stip for 23 or 63. Thoughts?

VR

ANGEL M. OVERGAARD
CPT, A

Trial Counsel, MDW

Fort McNair, DC

Page 269 of 2169

01587

Classification: UNCLASSIFIED
Caveats: NONE

Page 270 of 2169

01588

From: Fein, Ashden MAJ USARMY MDW (US)
To: Tooman, ,(gehue David r Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: Stip-Bigelow
Date: Sunday, June 16, 2013 4:31:00 PM

Attachments: 130616 of Exoected Testimony (BigelowP).docx



Gents,
Bigelow attached. We accepted all your changes and made a few accuracy edits.

V/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips- Bigelow

Sir,
Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips- Bigelow

Gents,

Attached is the Bigelow Stip.

Page 271 of 2169

01589

V/r
Ashden

Page 272 of 2169

01590

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman, David r Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY

USAMDW (US)
Subject: Stip-Downey
Date: Sunday, June 16, 2013 4:12:00 PM

Attachments: 130616 of Exgected Testimony (DowneyJ).docx

Gents,
Downey attached.

V/r
MAJ Fein

Page 273 of 2169

01591



From: FeinI Ashden MAJ USARMY MDW (US)

To: TQQman, (195mg QPT LJSARMY David Th MA ARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)

Bcc:

Subject: Stip-Harward

Date: Sunday, June 16, 2013 4:07:00 PM

Attachments: 130616 of Exgected Testimony (HarwardR).docx

Gents,

Harward attached.

V/r
MAJ Fein

Page 274 of 2169

01592

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman, ,(gehue David r Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: Stip-Williamson
Date: Sunday, June 16, 2013 4:01:00 PM

Attachments: 130616 of Exoected Testimony (WilliamsonA).docx



Gents,
Williamson attached.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 16, 2013 2:38 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)
Subject: RE: Stips- Bigelow

Sir,
Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 2:06 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips- Bigelow
Gents,

Attached is the Bigelow Stip.
V/r

Ashden

Page 275 of 2169

01593

Page 276 of 2169

01594





From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW David gagmbs; r Th MA ARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)

Subject: RE: Stips- Bigelow

Date: Sunday, June 16, 2013 2:37:46 PM

Attachments: SSG Bigelow.docx

Sir,

Here is the Bigelow stip that we would sign.

Thanks,

CPT Tooman



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 2:06 PM
To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc:

USARMY Morrow, oDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: Stips- Bigelow

Gents,

Attached is the Bigelow Stip.

V/r
Ashden

Page 277 of 2169

01595



From: Fein, Ashden MAJ USARMY MDW (US)

To: David mgmpe; Hurley, Thgmae TQQman, ,ggehua ,1 QPT

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)

Bcc:

Subject: Stips- Bigelow

Date: Sunday, June 16, 2013 2:06:00 PM

Attachments: 130616 of Exgected Testimony (BigelowP).docx

Gents,

Attached is the Bigelow Stip.

V/r
Ashden

Page 278 of 2169

01596



From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas USARMY Tooman, ,(gehue ,1ng USARMY
.051

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)

Subject: RE: Stips Update

Date: Sunday, June 16, 2013 12:16:58 PM

Ashden,

We would need to know when and why in 2013 the NCD was pulled off of JWICS
if that is the case. I could imagine that it was pulled simply because of

funding considerations. If this is the case, we would need to state that

this has nothing to do with the charged conduct of PFC Manning, and we would
also need to state that the same information is now available on other

reporting databases or channels.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 12:10 PM
To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT

USARMY (US)

Cc:

USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY



USARMY USAMDW (US)
Subject: RE: Stips Update

David,

I understand. I think the confusion is set on whether the cables themselves
are available through other reporting, vice through NCD. NCD was severed

Page 279 of 2169

01597

and no longer exists. We will find someone on our witness list who could

let you know that. The cables themselves are still and have remained

available through other legacy systems, as AMB Kennedy's testimony stated.
We are not disputing that the cables remain available to the Department of
State employees and others in the USG through legacy systems, just that they
do not remain available on NCD because NCD no longer exists on any network.

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Sunday, June 16, 2013 12:07 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We would need to speak with someone with knowledge regarding whether the
NCD was severed from JWICS during 2013 and whether it is currently available
through other reporting channels in order to agree with any change.
Additionally, assuming that the NCD is not on JWICS or other reporting
channels, we would need to include the reasoning for this late change and
whether reporting is now accomplished in some other manner.

As for the statements of the witnesses, if the witnesses' testimony is now
different from what they have previously told us, you would need to bring
them so that we can cross them on their previous statements.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



Page 280 of 2169

01598

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 12:00 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

Ambassador Kennedy's testimony was more than 2 years ago. Since then, NCD
was removed from JWICS during the first half of 2013. It was removed from
SIPRNET before that, and the global usage on SIPRNET was severed after
Thanksgiving 2010. As for the statement, we are verifying with the

witnesses. If they do not agree, we will call them as witnesses as per your
email. Assuming they don't agree, would the defense like to have a

conference call with each one and ask the question to them in order to be
comfortable stipulating?

I will let you know the outcome of our phone call with them, once we
connect.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 16, 2013 11:53 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

The NCD database still exists on JWICS and other distribution channels
according to the congressional testimony of AMB Kennedy, and our discussions
with DOS witnesses. We would not agree to referring to NCD in the past

tense. Additionally, the witnesses would say that there was no express or
implied restriction on the manner of downloading of the cables. Unless

these facts are a part of the stipulation, we would not agree to stipulate

to their testimony.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Page 281 of 2169

01599

Toll Free: 1-800-5 88-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 11:43 AM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

We reviewed the Johnson and Wisecarver stips. We changed all references to
NCD to the past tense because NCD no longer exists. I explained to MAJ
Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or
shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the
one line about "express or implied prohibition" with the witnesses. We do
not believe they would testify to that fact, and would actually testify to

the contrary. Hopefully we will be able to get a hold of them today to
verify that fact. If they agree, we will send back the final version with

past tense added back in. If they disagree, we will capture their summary
the best we can and send it back to you.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Page 282 of 2169

01600

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the POC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

anek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still
drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and



Page 283 of 2169

01601

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with DOS for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. BigelOW-still drafting (estimate Sunday
delivery by 1400)

Page 284 of 2169

01602



From: David Coombs

To: in A MA ARMY MDW
Subject: RE: Stips Update

Date: Sunday, June 16, 2013 12:16:23 PM
Ashden,

We would need to know when and why in 2013 the NCD was pulled off of JWICS
if that is the case. I could imagine that it was pulled simply because of

funding considerations. If this is the case, we would need to state that

this has nothing to do with the charged conduct of PFC Manning, and we would
also need to state that the same information is now available on other

reporting databases or channels.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 12:10 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

I understand. I think the confusion is set on whether the cables themselves
are available through other reporting, vice through NCD. NCD was severed
and no longer exists. We will find someone on our witness list who could
let you know that. The cables themselves are still and have remained
available through other legacy systems, as AMB Kennedy's testimony stated.
We are not disputing that the cables remain available to the Department of

Page 285 of 2169

01603

State employees and others in the USG through legacy systems, just that they
do not remain available on NCD because NCD no longer exists on any network.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 16, 2013 12:07 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We would need to speak with someone with knowledge regarding whether the
NCD was severed from JWICS during 2013 and whether it is currently available
through other reporting channels in order to agree with any change.
Additionally, assuming that the NCD is not on JWICS or other reporting
channels, we would need to include the reasoning for this late change and
whether reporting is now accomplished in some other manner.

As for the statements of the witnesses, if the witnesses' testimony is now
different from what they have previously told us, you would need to bring
them so that we can cross them on their previous statements.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 12:00 PM
To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Page 286 of 2169

01604

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

Ambassador Kennedy's testimony was more than 2 years ago. Since then, NCD
was removed from JWICS during the first half of 2013. It was removed from
SIPRNET before that, and the global usage on SIPRNET was severed after
Thanksgiving 2010. As for the statement, we are verifying with the

witnesses. If they do not agree, we will call them as witnesses as per your
email. Assuming they don't agree, would the defense like to have a

conference call with each one and ask the question to them in order to be
comfortable stipulating?

I will let you know the outcome of our phone call with them, once we
connect.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 16, 2013 11:53 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

The NCD database still exists on JWICS and other distribution channels
according to the congressional testimony of AMB Kennedy, and our discussions
with DOS witnesses. We would not agree to referring to NCD in the past

tense. Additionally, the witnesses would say that there was no express or
implied restriction on the manner of downloading of the cables. Unless

these facts are a part of the stipulation, we would not agree to stipulate

to their testimony.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com

Page 287 of 2169

01605



>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 11:43 AM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

We reviewed the Johnson and Wisecarver stips. We changed all references to
NCD to the past tense because NCD no longer exists. I explained to MAJ
Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or
shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the
one line about "express or implied prohibition" with the witnesses. We do
not believe they would testify to that fact, and would actually testify to

the contrary. Hopefully we will be able to get a hold of them today to
verify that fact. If they agree, we will send back the final version with

past tense added back in. If they disagree, we will capture their summary
the best we can and send it back to you.

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

Page 288 of 2169

01606

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

Janek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still



Page 289 of 2169

01607

drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. BigelOW-still drafting (estimate Sunday
delivery by 1400)

Page 290 of 2169

01608

From: Fein, Ashden MAJ USARMY MDW (US)
To: Hurley, Thomas MAJ USARMY David mgmpe; Tooman, ,(gehue QPT USARMY (us)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: RE: Stips Update
Date: Sunday, June 16, 2013 12:12:00 PM

Attachments: 130614 of Expected Testimony (MotesJ)
130612 of Expected Testimony (AllenM)
130613 of Expected Testimony (ThianT) (Encl)
130613 of Expected Testimony (ThianT)



MAJ Hurley,

1. Collins is going to be rolled up in Downey, so we do not expect to call him if there is a signed stipulation for
Downey.

2. Motes attached.
3. Thian attached with PE enclosures
4. Allen attached.

More stips to follow throughout the day, including the ones listed below. Also, as per our discussion outside, we
will setup all the PBS and other references the stips make for the accused and counsel to reView prior to the MJ's
colloquy. We will layout the information in a manner similar to Nehring and Hoskins to make it easier for all
parties.

V/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 16, 2013 12:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

All

Here are the stipulations I believe we can get signed by the client today:
Strobl

Allen

Motes

Woods
Thian

Page 291 of 2169

01609

Collins (this guy is on AB 566 as a witness and potential stip but not on the rundown you sent on Friday - do you
still want to call and stip or not going to call at all?)

Downey

Bigelow

Williamson

Please forward me clean copies of Allen (I marred the copy I have and can't find the final version in the email
exchanges), Motes, Thian. We will work this afternoon on Downey, Bigelow, and Williamson.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 3:43 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

David,

We reviewed the Johnson and Wisecarver stips. We changed all references to NCD to the past tense because NCD
no longer exists. I explained to MAJ Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the one line about "express or implied
prohibition" with the witnesses. We do not believe they would testify to that fact, and would actually testify to the
contrary. Hopefully we will be able to get a hold of them today to verify that fact. If they agree, we will send back
the final version with past tense added back in. If they disagree, we will capture their summary the best we can and
send it back to you.

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,
We have made additional changes to the Mr. Wisecarver and Dr. Johnson's

stip. Please see the attached document. If the Government does not agree
with these additional changes, it will be necessary to bring Mr. Wisecarver

Page 292 of 2169

and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

Janek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting



Page 293 of 2169

01610

01611

(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. BigelOW-still drafting (estimate Sunday
delivery by 1400)

Page 294 of 2169

01612

From: Fein, Ashden MAJ USARMY MDW (US)
To: "David Th MA ARMY PT ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: RE: Stips Update
Date: Sunday, June 16, 2013 12:10:00 PM



David,

I understand. I think the confusion is set on whether the cables themselves are available through other reporting,
vice through NCD. NCD was severed and no longer exists. We will find someone on our witness list who could let
you know that. The cables themselves are still and have remained available through other legacy systems, as AMB
Kennedy's testimony stated. We are not disputing that the cables remain available to the Department of State
employees and others in the USG through legacy systems, just that they do not remain available on NCD because
NCD no longer exists on any network.

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Sunday, June 16, 2013 12:07 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We would need to speak with someone with knowledge regarding whether the
NCD was severed from JWICS during 2013 and whether it is currently available
through other reporting channels in order to agree with any change.
Additionally, assuming that the NCD is not on JWICS or other reporting
channels, we would need to include the reasoning for this late change and
whether reporting is now accomplished in some other manner.

As for the statements of the witnesses, if the witnesses' testimony is now
different from what they have previously told us, you would need to bring
them so that we can cross them on their previous statements.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Page 295 of 2169

01613

Fax: (508) 689-9282
coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 12:00 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

Ambassador Kennedy's testimony was more than 2 years ago. Since then, NCD
was removed from JWICS during the first half of 2013. It was removed from
SIPRNET before that, and the global usage on SIPRNET was severed after
Thanksgiving 2010. As for the statement, we are verifying with the

witnesses. If they do not agree, we will call them as witnesses as per your
email. Assuming they don't agree, would the defense like to have a

conference call with each one and ask the question to them in order to be
comfortable stipulating?

I will let you know the outcome of our phone call with them, once we
connect.

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Sunday, June 16, 2013 11:53 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

The NCD database still exists on JWICS and other distribution channels
according to the congressional testimony of AMB Kennedy, and our discussions

Page 296 of 2169

with DOS witnesses. We would not agree to referring to NCD in the past
tense. Additionally, the witnesses would say that there was no express or
implied restriction on the manner of downloading of the cables. Unless
these facts are a part of the stipulation, we would not agree to stipulate

to their testimony.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 11:43 AM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

We reviewed the Johnson and Wisecarver stips. We changed all references to
NCD to the past tense because NCD no longer exists. I explained to MAJ
Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or
shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the
one line about "express or implied prohibition" with the witnesses. We do
not believe they would testify to that fact, and would actually testify to

the contrary. Hopefully we will be able to get a hold of them today to
verify that fact. If they agree, we will send back the final version with

past tense added back in. If they disagree, we will capture their summary
the best we can and send it back to you.

v/r
Ashden

Page 297 of 2169

01614

01615



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,
We have the classified computer ready to sign over tomorrow morning after

1030. - is the POC and will be in the trailer. Below is an update
on all stips we are tracking.

Page 298 of 2169

01616

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

anek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. Bigelow-still drafting (estimate Sunday
delivery by 1400)



Page 299 of 2169

01617

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas USARMY Tooman, ,(gehue ,1ng USARMY
.051

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY

USAMDW (US)
Subject: RE: Stips Update
Date: Sunday, June 16, 2013 12:06:58 PM



Ashden,

We would need to speak with someone with knowledge regarding whether the
NCD was severed from JWICS during 2013 and whether it is currently available
through other reporting channels in order to agree with any change.
Additionally, assuming that the NCD is not on JWICS or other reporting
channels, we would need to include the reasoning for this late change and
whether reporting is now accomplished in some other manner.

As for the statements of the witnesses, if the witnesses' testimony is now
different from what they have previously told us, you would need to bring
them so that we can cross them on their previous statements.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 12:00 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Page 300 of 2169

01618

David,

Ambassador Kennedy's testimony was more than 2 years ago. Since then, NCD
was removed from JWICS during the first half of 2013. It was removed from
SIPRNET before that, and the global usage on SIPRNET was severed after
Thanksgiving 2010. As for the statement, we are verifying with the

witnesses. If they do not agree, we will call them as witnesses as per your
email. Assuming they don't agree, would the defense like to have a

conference call with each one and ask the question to them in order to be
comfortable stipulating?

I will let you know the outcome of our phone call with them, once we
connect.

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Sunday, June 16, 2013 11:53 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

The NCD database still exists on JWICS and other distribution channels
according to the congressional testimony of AMB Kennedy, and our discussions
with DOS witnesses. We would not agree to referring to NCD in the past

tense. Additionally, the witnesses would say that there was no express or
implied restriction on the manner of downloading of the cables. Unless

these facts are a part of the stipulation, we would not agree to stipulate

to their testimony.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying

Page 301 of 2169

01619

or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 11:43 AM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

We reviewed the Johnson and Wisecarver stips. We changed all references to
NCD to the past tense because NCD no longer exists. I explained to MAJ
Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or
shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the
one line about "express or implied prohibition" with the witnesses. We do
not believe they would testify to that fact, and would actually testify to

the contrary. Hopefully we will be able to get a hold of them today to
verify that fact. If they agree, we will send back the final version with

past tense added back in. If they disagree, we will capture their summary
the best we can and send it back to you.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver

and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Page 302 of 2169

01620

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

Janek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. Bigelow-still drafting (estimate Sunday
delivery by 1400)



Page 303 of 2169

01621

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW David Tooman, ,(gehue ,1ng
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Subject: RE: Stips Update
Date: Sunday, June 16, 2013 12:01:21 PM



All
Here are the stipulations I believe we can get signed by the client today:

Strobl

Allen

Motes

Woods

Thian

Collins (this guy is on AB 566 as a witness and potential stip but not on the rundown you sent on Friday - do you
still want to call and stip or not going to call at all?)

Downey

Bigelow

Williamson

Please forward me clean copies of Allen (I marred the copy I have and can't find the final version in the email
exchanges), Motes, Thian. We will work this afternoon on Downey, Bigelow, and Williamson.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 3:43 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

David,

We reviewed the Johnson and Wisecarver stips. We changed all references to NCD to the past tense because NCD
no longer exists. I explained to MAJ Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the one line about "express or implied
prohibition" with the witnesses. We do not believe they would testify to that fact, and would actually testify to the
contrary. Hopefully we will be able to get a hold of them today to verify that fact. If they agree, we will send back
the final version with past tense added back in. If they disagree, we will capture their summary the best we can and
send it back to you.

Page 304 of 2169

01622

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the POC and will be in the trailer. Below is an update

Page 305 of 2169

01623

on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

anek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. Bigelow-still drafting (estimate Sunday
delivery by 1400)



Page 306 of 2169

01624

From: Fein, Ashden MAJ USARMY MDW (US)
To: "David Th MA ARMY PT ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: RE: Stips Update
Date: Sunday, June 16, 2013 11:59:00 AM



David,

Ambassador Kennedy's testimony was more than 2 years ago. Since then, NCD was removed from JWICS during
the first half of 2013. It was removed from SIPRNET before that, and the global usage on SIPRNET was severed
after Thanksgiving 2010. As for the statement, we are verifying with the witnesses. If they do not agree, we will
call them as witnesses as per your email. Assuming they don't agree, would the defense like to have a conference
call with each one and ask the question to them in order to be comfortable stipulating?

I will let you know the outcome of our phone call with them, once we connect.

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Sunday, June 16, 2013 11:53 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

The NCD database still exists on WICS and other distribution channels
according to the congressional testimony of AMB Kennedy, and our discussions
with DOS witnesses. We would not agree to referring to NCD in the past

tense. Additionally, the witnesses would say that there was no express or
implied restriction on the manner of downloading of the cables. Unless

these facts are a part of the stipulation, we would not agree to stipulate

to their testimony.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com

Page 307 of 2169

01625



>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 16, 2013 11:43 AM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

David,

We reviewed the Johnson and Wisecarver stips. We changed all references to
NCD to the past tense because NCD no longer exists. I explained to MAJ
Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or
shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the
one line about "express or implied prohibition" with the witnesses. We do
not believe they would testify to that fact, and would actually testify to

the contrary. Hopefully we will be able to get a hold of them today to
verify that fact. If they agree, we will send back the final version with

past tense added back in. If they disagree, we will capture their summary
the best we can and send it back to you.

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

Page 308 of 2169

01626

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

Janek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still



Page 309 of 2169

01627

drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. BigelOW-still drafting (estimate Sunday
delivery by 1400)

Page 310 of2169

01628



From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas USARMY Tooman, ,(gehua ,1 QPT USARMY


Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)

Subject: RE: Stips Update

Date: Sunday, June 16, 2013 11:53:16 AM

Attachments: Kennedy 2.mp4

Ashden,

The NCD database still exists on WICS and other distribution channels
according to the congressional testimony of AMB Kennedy, and our discussions
with DOS witnesses. We would not agree to referring to NCD in the past

tense. Additionally, the witnesses would say that there was no express or
implied restriction on the manner of downloading of the cables. Unless

these facts are a part of the stipulation, we would not agree to stipulate

to their testimony.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 16, 2013 11:43 AM
To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT

USARMY (US)

Cc:

USARMY Morrow, oDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY



USARMY USAMDW (US)
Subject: RE: Stips Update

David,

Page 311 of2169

01629

We reviewed the Johnson and Wisecarver stips. We changed all references to
NCD to the past tense because NCD no longer exists. I explained to MAJ
Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or
shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the
one line about "express or implied prohibition" with the witnesses. We do
not believe they would testify to that fact, and would actually testify to

the contrary. Hopefully we will be able to get a hold of them today to
verify that fact. If they agree, we will send back the final version with

past tense added back in. If they disagree, we will capture their summary
the best we can and send it back to you.

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



Page 312 of2169

01630

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

Janek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. Bigelow-still drafting (estimate Sunday
delivery by 1400)



Page 313 of2169

01631

From: Fein, Ashden MAJ USARMY MDW (US)
To: "David Th MA ARMY PT ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY USARMY



USAMDW (US)
Bcc:
Subject: RE: Stips Update
Date: Sunday, June 16, 2013 11:43:00 AM



David,

We reviewed the Johnson and Wisecarver stips. We changed all references to NCD to the past tense because NCD
no longer exists. I explained to MAJ Hurley a little bit ago, that NCD was terminated on all networks, therefore
any references need to be in the past, or "as of the date of compromise or shortly thereafter."

Overall, we have no issues with the edits; however we have to check on the one line about "express or implied
prohibition" with the witnesses. We do not believe they would testify to that fact, and would actually testify to the
contrary. Hopefully we will be able to get a hold of them today to verify that fact. If they agree, we will send back
the final version with past tense added back in. If they disagree, we will capture their summary the best we can and
send it back to you.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Saturday, June 15, 2013 11:09 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


Page 314 of2169

01632

>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

Janek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. Bigelow-still drafting (estimate Sunday
delivery by 1400)



Page 315 of2169

01633

From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ USARMY Tooman, (Joshua ,1 QPT USARMY


Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY

USAMDW (US)
Subject: Re: Stips Update
Date: Saturday, June 15, 2013 11:52:13 AM



Thank you. We will review and get back to you.

Original Message

From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Saturday, June 15, 2013 11:08 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY USAMDW (US)

Subject: RE: Stips Update

Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. Johnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as Witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY

Page 316 of2169

01634

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,

We have the classified computer ready to sign over tomorrow morning after
1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

Janek-waiting to hear back from him

9. Mundy-waiting to hear back from him

10. Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.
Downey-still drafting (estimate Sunday delivery by 1400) 21. Harward-still
drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. Bigelow-still drafting (estimate Sunday
delivery by 1400)



Page 317 of2169

01635

From: Fein Ashden MAJ USARMY MDW (US)
To: Th FMA ARMY ;ngman Jeanna
rm rmril fn . m"
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)



Subject: Re: Stips

Date: Saturday, June 15, 2013 11:52:12 AM
Thank you.

Original Message

From: Hurley, Thomas MAJ USARMY (US)

Sent: Saturday, June 15, 2013 11:42 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs



Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

MAJ Fein
The Motes stip is good.

v/r
t??l



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, June 14, 2013 7:39 PM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

Gents,

Attached is our iteration with tracked changes for Motes. We spoke to him today to get the clarification on the parts
you added.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, June 14, 2013 3:15 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

Sir

Page 318 of2169

01636

You'd previously asked if we are willing to stip to Bigelow, Williamson, and CDR Aboul-Enein. The answer is yes.

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 13, 2013 7:36 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are the following stips:

1. Motes returned. We spoke with him today and obtained some clarity on a few points. Changes are tracked.

2. Johnson

3. Wisecarver

Our plan is to still have us agree on State stips and then after the defense and accused sign them, we will send them
to the Department for clearance; however I am sending Mr. Murphy's first to them, because it is very technical
when it comes to classification and I think it would be a waste of our time to go back and forth on it, if needed,

before he gets a copy. I am sending that one to the Department tonight.

v/r
Ashden

Page 319 of2169

01637

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW Tooman, ,(gehue QPT USARMY David mgmpe
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stips
Date: Saturday, June 15, 2013 11:42:05 AM
MAJ Fein

The Motes stip is good.

v/r
t??l



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, June 14, 2013 7:39 PM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

Gents,

Attached is our iteration with tracked changes for Motes. We spoke to him today to get the clarification on the parts
you added.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, June 14, 2013 3:15 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

Sir

You'd previously asked if we are willing to stip to Bigelow, Williamson, and CDR Aboul-Enein. The answer is yes.

Josh



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Thursday, June 13, 2013 7:36 PM
To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Page 320 of 2169

01638

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are the following stips:

1. Motes returned. We spoke with him today and obtained some clarity on a few points. Changes are tracked.

2. Johnson

3. Wisecarver

Our plan is to still have us agree on State stips and then after the defense and accused sign them, we will send them
to the Department for clearance; however I am sending Mr. Murphy's first to them, because it is very technical
when it comes to classification and I think it would be a waste of our time to go back and forth on it, if needed,

before he gets a copy. I am sending that one to the Department tonight.

V/r
Ashden

Page 321 of 2169

01639

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas USARMY Tooman, ,(gehue QPT USARMY
ALE)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY

USAMDW (US)
Subject: RE: Stips Update
Date: Saturday, June 15, 2013 11:09:06 AM
Attachments: Wisecarver Stip.docx

Johnson Stip.docx



Ashden,

We have made additional changes to the Mr. Wisecarver and Dr. ohnson's
stip. Please see the attached document. If the Government does not agree

with these additional changes, it will be necessary to bring Mr. Wisecarver
and Dr. Johnson as witnesses.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, June 14, 2013 6:21 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY
USARMY USAMDW (US)

Subject: Stips Update

Gents,
We have the classified computer ready to sign over tomorrow morning after

1030. - is the FCC and will be in the trailer. Below is an update
on all stips we are tracking.

Page 322 of 2169



9.
10.

01640

Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer

Yavonovitch-on computer

Pittman-on computer

#107-on computer

anek-waiting to hear back from him

Mundy-waiting to hear back from him

Seche-still drafting (estimate Sunday delivery) 11. Feeley-still

drafting (estimate Sunday delivery) 12. Woods-defense 13. Motes-defense 14.
ohnson-will edit and verify this weekend 15. Wisecarver-will edit and

verify this weekend 16. Thian-agreed upon and with defense 17. Strobl-agreed
upon and with government for printing because classified 18. Allen-agreed
upon and with defense 19. Murphy-with for technical review 20.

Do

wney-still drafting (estimate Sunday delivery by 1400) 21. Harward-still

drafting (estimate Sunday delivery by 1400) 22. Aboul-Enein-still drafting
(estimate Sunday delivery by 1400) 23. Williamson-still drafting (estimate
Sunday delivery by 1400) 24. Bigelow-still drafting (estimate Sunday

del

Page

ivery by 1400)

3230f2169

01641





From: Fein, Ashden MAJ USARMY MDW (US)

To: David (329mm; r Th MA ARMY ngman, lJoshua ,1 QPT LJSARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY USARMY
USAMDW (US)

Bcc:

Subject: Stips Update

Date: Friday, June 14, 2013 6:21:00 PM

Gents,

We have the classified computer ready to sign over tomorrow morning after 1030. - is the FCC and will
be in the trailer. Below is an update on all stips we are tracking.



Pearce-on computer

Yamamoto-on computer

Yun-on computer

Moore-on computer
Yavonovitch-on computer
Pittman-on computer

#107-on computer

anek-waiting to hear back from him

9. Mundy-waiting to hear back from him
10. Seche-still drafting (estimate Sunday delivery)
11. Feeley-still drafting (estimate Sunday delivery)

12. Woods-defense
13. Motes-defense

14. ohnson-will edit and verify this weekend

15. Wisecarver-will edit and verify this weekend

16. Thian-agreed upon and with defense

17. Strobl-agreed upon and with government for printing because classified
18. Allen-agreed upon and with defense

19. Murphy-with for technical review

20. Downey-still drafting (estimate Sunday delivery by 1400)

21. Harward-still drafting (estimate Sunday delivery by 1400)

22. Aboul-Enein-still drafting (estimate Sunday delivery by 1400)
23. Williamson-still drafting (estimate Sunday delivery by 1400)
24. Bigelow-still drafting (estimate Sunday delivery by 1400)

Page 324 of 2169

01642

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman ,(gemta Th FMA ARMY ;David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)





Subject: RE: Stips

Date: Friday, June 14, 2013 3:39:00 PM

Attachments: 130614 of Exoected Testimony (MotesJ).docx
Gents,

Attached is our iteration with tracked changes for Motes. We spoke to him today to get the clarification on the parts
you added.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, June 14, 2013 3:15 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

Sir

You'd previously asked if we are willing to stip to Bigelow, Williamson, and CDR Aboul-Enein. The answer is yes.

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 13, 2013 7:36 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,
Attached are the following stips:
1. Motes returned. We spoke with him today and obtained some clarity on a few points. Changes are tracked.

2. Johnson

Page 325 of 2169

01643

3. Wisecarver

Our plan is to still have us agree on State stips and then after the defense and accused sign them, we will send them
to the Department for clearance; however I am sending Mr. Murphy's first to them, because it is very technical
when it comes to classification and I think it would be a waste of our time to go back and forth on it, if needed,
before he gets a copy. I am sending that one to the Department tonight.

V/r
Ashden

Page 326 of 2169

01644

From: Fein, Ashden MAJ USARMY MDW (US)
To: Tooman, ,(gehue r Th FMA ARMY ;David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

Date: Friday, June 14, 2013 3:17:00 PM



Thanks. We will have them ready by Sunday. I will send a roll-up of what we have in a few hours. We will have a
classified laptop to hand to ya'll tomorrow with most of all the State Stips ready for review.



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, June 14, 2013 3:15 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY David Coombs

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

Sir

You'd previously asked if we are willing to stip to Bigelow, Williamson, and CDR Aboul-Enein. The answer is yes.

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 13, 2013 7:36 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are the following stips:

1. Motes returned. We spoke with him today and obtained some clarity on a few points. Changes are tracked.

2. Johnson

3. Wisecarver

Our plan is to still have us agree on State stips and then after the defense and accused sign them, we will send them

to the Department for clearance; however I am sending Mr. Murphy's first to them, because it is very technical
when it comes to classification and I think it would be a waste of our time to go back and forth on it, if needed,

Page 327 of 2169

01645

before he gets a copy. I am sending that one to the Department tonight.

V/r
Ashden

Page 328 of 2169

01646

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW r Th FMA ARMY ;David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stips
Date: Friday, June 14, 2013 3:16:03 PM
Sir

You'd previously asked if we are willing to stip to Bigelow, Williamson, and CDR Aboul-Enein. The answer is yes.

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 13, 2013 7:36 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are the following stips:

1. Motes returned. We spoke with him today and obtained some clarity on a few points. Changes are tracked.

2. Johnson

3. Wisecarver

Our plan is to still have us agree on State stips and then after the defense and accused sign them, we will send them
to the Department for clearance; however I am sending Mr. Murphy's first to them, because it is very technical
when it comes to classification and I think it would be a waste of our time to go back and forth on it, if needed,

before he gets a copy. I am sending that one to the Department tonight.

v/r
Ashden

Page 329 of 2169

01647

From: Tooman, Joshua CPT USARMY (US)
To: Fem, Ashden MAJ USARMY MDW r Th FMA ARMY David
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips
Date: Friday, June 14, 2013 11:26:01 AM
Attachments: Wisecarver Stio.docx

Motes Stio.docx
Johnson Stio.docx



All

Attached are the Johnson, Motes, and Wisecarver stips with Defense notes.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 13, 2013 7:36 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are the following stips:

1. Motes returned. We spoke with him today and obtained some clarity on a few points. Changes are tracked.

2. Johnson

3. Wisecarver

Our plan is to still have us agree on State stips and then after the defense and accused sign them, we will send them
to the Department for clearance; however I am sending Mr. Murphy's first to them, because it is very technical
when it comes to classification and I think it would be a waste of our time to go back and forth on it, if needed,

before he gets a copy. I am sending that one to the Department tonight.

V/r
Ashden

Page 330 of 2169

01648

From: Fein, Ashden MAJ USARMY MDW (US)
To: r Th MA ARMY David mgmpe; TQQman, ,(gehue QPT (us)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips
Date: Thursday, June 13, 2013 7:36:00 PM

Attachments: 130613 of Expected Testimony (JohnsonG).docx
130613 of Expected Testimony (WisecarverC).docx
130613 of Expected Testimony (MotesJ).docx





Gents,

Attached are the following stips:

1. Motes returned. We spoke with him today and obtained some clarity on a few points. Changes are tracked.

2. Johnson

3. Wisecarver

Our plan is to still have us agree on State stips and then after the defense and accused sign them, we will send them
to the Department for clearance; however I am sending Mr. Murphy's first to them, because it is very technical
when it comes to classification and I think it would be a waste of our time to go back and forth on it, if needed,

before he gets a copy. I am sending that one to the Department tonight.

V/r
Ashden

Page 331 of 2169

01649



From: Hurley, Thomas MAJ USARMY (US)

To: in A MA ARMY MDW David Q?ngbs; Tooman, (Joshua ,1 QPT USARMY (LJS)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

Date: Thursday, June 13, 2013 3:15:08 PM

Attachments: Motes Stipulation with Defense Changesdocx

All

Here's the Motes stipulation. I really fudged up the 'track changes' function on this one. I highlighted my additions
by making them the color red. I also changed a "may" to a "could" in paragraph 17.

Also, could we add the last two paragraphs on the Woods stipulation to this one? One of the paragraphs I hand-
wrote and gave back to you today. The other was the last paragraph about some of the being released in

2007.

Thanks.

MAJ Hurley



From: Hurley, Thomas MAJ USARMY (US)
Sent: Thursday, June 13, 2013 6:04 PM
To: Fein, Ashden MAJ USARMY MDW David Coombs; Tooman, Joshua CPT USARMY (US)

Cc:

USARMY Morrow, oDean (Joe) CPT USARMY USAMDW

Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

MAJ Fein

I am fine with the changes to Thian.

V/r

Page 332 of 2169

01650





From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 13, 2013 6:01 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

MAJ Hurley,

Thanks. We received your notes and are working on the updates. Wisecarver and Johnson are almost finished and I
expect to have those out in the next hour. We are also finalizing Murphy, Harward, Downey, and #107.

Attached is Thian and is updated pursuant to our discussions.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Thursday, June 13, 2013 1:59 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

MAJ Fein

I am still working on:

Motes

I have returned with notes:
RDML Woods
anek

Mundy

I will ask the client to review:
Strobl

Allen

Page 333 of 2169

01651

Is Johnson or Wisecarver completed?

Going forward, I would like to have all of the PEs that are referenced in a stip available for review by the client prior
to signing. If that is too unweildy, then I would like a chance for the client to review everything prior to
publication.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, June 12, 2013 12:24 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are Motes and Allen. We also have Strobl, Mundy, and anak that are classified for your review. Johnson
and Wisecarver should be ready by lunch.

v/r
Ashden

Page 334 of 2169

01652

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW David Tooman, ,(gehue QPT USARMY (us)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stips
Date: Thursday, June 13, 2013 2:04:18 PM
MAJ Fein

I am fine with the changes to Thian.

v/r





From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 13, 2013 6:01 PM

To: Hurley, Thomas MAJ USARMY David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stips

MAJ Hurley,

Thanks. We received your notes and are working on the updates. Wisecarver and Johnson are almost finished and I
expect to have those out in the next hour. We are also finalizing Murphy, Harward, Downey, and #107.

Attached is Thian and is updated pursuant to our discussions.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Thursday, June 13, 2013 1:59 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

MAJ Fein

I am still working on:

Page 335 of 2169

01653

Motes

I have returned with notes:
RDML Woods
anek

Mundy

I will ask the client to review:

Strobl

Allen

Is Johnson or Wisecarver completed?

Going forward, I would like to have all of the PEs that are referenced in a stip available for review by the client prior
to signing. If that is too unweildy, then I would like a chance for the client to review everything prior to
publication.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, June 12, 2013 12:24 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are Motes and Allen. We also have Strobl, Mundy, and anak that are classified for your review. Johnson
and Wisecarver should be ready by lunch.

v/r
Ashden

Page 336 of 2169

01654

Page 337 of 2169

01655

From: Hurley, Thomas MAJ USARMY (US)

To: rr PT ARMY AMDW ;Fein Aengen David
PT ARMY

Cc: USARMY Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Ellen, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
- USARMY (US)



Subject: RE: Stips (UNCLASSIFIED)
Date: Thursday, June 13, 2013 2:01:56 PM
CPT Morrow

Apologies for the confusion. Please add paragraph 12 and make the old paragraph 12 paragraph 13.

V/r





From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, June 13, 2013 6:00 PM

To: Hurley, Thomas MAJ USARMY Fein, Ashden MAJ USARMY MDW David Coombs; Tooman,

Joshua CPT USARMY (US)

Cc: USARMY Overgaard, Angel CPT USARMY Whyte, Hunter CPT

USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stips (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

MAJ Hurley,

I'm confused by your notes on RDML Woods. Would you like paragraph 12 to
replace the old paragraph 12 or to supplement?

CPT Joe Morrow
Trial Counsel
US. Army Military District of Washington





From: Hurley, Thomas MAJ USARMY (US)

Sent: Thursday, June 13, 2013 1:59 PM

To: Fein, Ashden MAJ USARMY MDW DaVid Coombs; Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

Page 338 of 2169

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine
CPT USARMY USARMY (US)

Subject: RE: Stips

MAJ Fein

I am still working on:

Motes

I have returned with notes:
RDML Woods
anek

Mundy
I will ask the client to review:

Strobl

Allen

Is Johnson or Wisecarver completed?

Going forward, I would like to have all of the PEs that are referenced in a
stip available for review by the client prior to signing. If that is too
unweildy, then I would like a chance for the client to review everything
prior to publication.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, June 12, 2013 12:24 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

Page 339 of 2169

01656

01657

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are Motes and Allen. We also have Strobl, Mundy, and anak that
are classified for your review. Johnson and Wisecarver should be ready by
lunch.

V/r

Ashden

Classification: UNCLASSIFIED
Caveats: NONE

Page 340 of 2169

01658

From: Fein, Ashden MAJ USARMY MDW (US)
To: Hurley Thomas MAJ David TQQman ,(ggmta QPT (US)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)

Subject: RE: Stips
Date: Thursday, June 13, 2013 2:00:00 PM

Attachments: 130613 of Expected Testimony (ThianT).docx
130613 of Expected Testimony (ThianT) (Encl.).docx





MAJ Hurley,

Thanks. We received your notes and are working on the updates. Wisecarver and Johnson are almost finished and I
expect to have those out in the next hour. We are also finalizing Murphy, Harward, Downey, and #107.

Attached is Thian and is updated pursuant to our discussions.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Thursday, June 13, 2013 1:59 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

MAJ Fein

I am still working on:

Motes

I have returned with notes:
RDML Woods
anek

Mundy

I will ask the client to review:
Strobl

Allen

Page 341 of 2169

01659

Is Johnson or Wisecarver completed?

Going forward, I would like to have all of the PEs that are referenced in a stip available for review by the client prior
to signing. If that is too unweildy, then I would like a chance for the client to review everything prior to
publication.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, June 12, 2013 12:24 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are Motes and Allen. We also have Strobl, Mundy, and anak that are classified for your review. Johnson
and Wisecarver should be ready by lunch.

v/r
Ashden

Page 342 of 2169

01660

From: Hurley, Thomas MAJ USARMY (US)
To: Fem, Ashden USARMY MDW David memes; TQQman, ,(gehua QPT USARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stips
Date: Thursday, June 13, 2013 1:58:40 PM
MAJ Fein

I am still working on:

Motes

I have returned with notes:
RDML Woods
anek

Mundy

I will ask the client to review:

Strobl

Allen

Is Johnson or Wisecarver completed?

Going forward, I would like to have all of the PEs that are referenced in a stip available for review by the client prior
to signing. If that is too unweildy, then I would like a chance for the client to review everything prior to
publication.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, June 12, 2013 12:24 PM

Page 343 of 2169

01661

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are Motes and Allen. We also have Strobl, Mundy, and anak that are classified for your review. Johnson
and Wisecarver should be ready by lunch.

V/r
Ashden

Page 344 of 2169

01662

From: Fein, Ashden MAJ USARMY MDW (US)
To: David mgmpe; Hurley, Thomas TQQman, ,(gehue QPT (us)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips
Date: Wednesday, June 12, 2013 8:24:00 AM

Attachments: 130612 of Exoected Testimony (Motes).docx
130612 (0821 )-Stiou ation of Exoected Testimony (AllenM).docx



Gents,

Attached are Motes and Allen. We also have Strobl, Mundy, and anak that are classified for your review. Johnson
and Wisecarver should be ready by lunch.

V/r
Ashden

Page 345 of 2169

01663

From: Hurley, Thomas MAJ USARMY (US)
To: El Al AI PT ARMY
Cc: David Coombs; Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW Morrow, JoDean

(Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
Mitroka, Katherine CPT USARMY USARMY

USARMY (US)
Subject: RE: Stips (UNCLASSIFIED)
Date: Monday, June 10, 2013 1:52:34 PM
Attachments: Larue with Defense Changesdocx



All
Here are the changes on the Larue stipulation.

v/r
t??l



From: von Elten, Alexander (Alec) CPT USARMY (US)

Sent: Monday, June 10, 2013 5:29 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: David Coombs; Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW Morrow,
oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY Mitroka, Katherine CPT USARMY USARMY

USARMY (US)

Subject: RE: Stips (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Sir,

It's attached.

Respectfully,

Alec von Elten



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 10, 2013 1:27 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY (US)
Subject: RE: Stips

MAJ Fein

Can you send me the for CW5 Larue?

Thanks.

MAJ Hurley

Page 346 of 2169

01664



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 10, 2013 12:11 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY
Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY wsx? USARMY am

Subject: RE: Stips
Gents,
Grant's is attached. We added the PE for ID language.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 10, 2013 7:14 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Fein

Some help would be great. I have no problem cold calling RADL Woods, but I think my identity and relationship to
this case would have to be verified by someone.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 10, 2013 2:35 AM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
MAJ Hurley,

I know I just sent the Stip back to you for review. If you would like us to assist with setting up a phone call, we will
start first thing tomorrow morning.

Page 347 of 2169

01665

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 6:31 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

One stip we haven't said much about is RADL Woods. I would like to have him validate the stipulation and
describe - in greater detail - his process of review. Do you have a good phone number for his aide? I anticipate that
this will take a couple of days to knock out through email or a phone call.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:50 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Hurley,
That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

Page 348 of 2169

01666

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Gents,

We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\ Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY am

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,

Page 349 of 2169

01667

Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.

Page 350 of 2169

01668

If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





>l<>l<>linformation and is intended for the

person(s) or company named. If you are not the intended recipient, please notify the sender and delete all copies.
Unauthorized disclosure, copying or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ USARMY Tooman,
Joshua CPT USARMY (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY wsx? USARMY USARMY
Subject: Stips
Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others and make classified ones available via
a classified laptop, so that you can track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you to review and let us know if there are
issues.

Also, after reviewing the remainder of the witnesses, is the defense willing to stipulate to Glenn, Wisecarver,
ohnsonG, and Larue?

Thanks!

v/r
Ashden

Classification: UNCLASSIFIED
Caveats: NONE

Page 351 of2169

01669

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW PT ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: RE: Stips
Date: Monday, June 10, 2013 1:26:56 PM
MAJ Fein

Can you send me the for CW5 Larue?
Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 10, 2013 12:11 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY
Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY USARMY

Subject: RE: Stips
Gents,
Grant's is attached. We added the PE for ID language.

V/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 10, 2013 7:14 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Fein

Some help would be great. I have no problem cold calling RADL Woods, but I think my identity and relationship to
this case would have to be verified by someone.

Thanks.

MAJ Hurley

Page 352 of 2169

01670



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 10, 2013 2:35 AM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Hurley,

I know I just sent the Stip back to you for review. If you would like us to assist with setting up a phone call, we will
start first thing tomorrow morning.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 6:31 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Fein

One stip we haven't said much about is RADL Woods. I would like to have him validate the stipulation and
describe - in greater detail - his process of review. Do you have a good phone number for his aide? I anticipate that
this will take a couple of days to knock out through email or a phone call.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:50 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Hurley,

Page 353 of 2169

01671

That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Fein

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Sir

Page 354 of 2169

01672

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

Page 355 of 2169

01673

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)
Subject: Stips
Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

Page 356 of 2169

01674

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 357 of 2169

01675

From: Fein Ashden MAJ USARMY MDW US
To: Th MA ARMY Tooman, (Joshua ,1 QPT USARMY David (329mm
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us ;?_c_xusmw us





Bcc:

Subject: RE: Stips

Date: Monday, June 10, 2013 8:11:00 AM

Attachments: 130610 of Expected Testimony (GrantJ).docx
Gents,

Grant's is attached. We added the PE for ID language.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 10, 2013 7:14 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Fein

Some help would be great. I have no problem cold calling RADL Woods, but I think my identity and relationship to
this case would have to be verified by someone.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 10, 2013 2:35 AM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Hurley,

I know I just sent the Stip back to you for review. If you would like us to assist with setting up a phone call, we will

Page 358 of 2169

01676

start first thing tomorrow morning.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 6:31 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

One stip we haven't said much about is RADL Woods. I would like to have him validate the stipulation and
describe - in greater detail - his process of review. Do you have a good phone number for his aide? I anticipate that
this will take a couple of days to knock out through email or a phone call.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:50 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Hurley,
That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Fein

Page 359 of 2169

01677

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY (US)

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Page 360 of 2169

01678

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Page 361 of 2169

01679

Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 362 of 2169

01680

Page 363 of 2169

01681

From: Fein Ashden MAJ USARMY MDW (US)
To: David Th FMA ARMY ;TQQman ,(ggmta
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)

Subject: RE: Stipulations
Date: Monday, June 10, 2013 7:48:00 AM

Attachments: 130610 of Expected Testimony (BoraW).docx





David,

No issues with Bora. I accepted all the changes and its attached. We will review Woods and setup the phone
meeting.

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Monday, June 10, 2013 6:59 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stipulations

Ashden,

I am verifying the changes you made on Ms. stipulation. Once
I hear back from her, I will let you know. With regards to the other
changes we will do the following:

Woods: I have attached an additional change based upon your addition. I
have also attached the supporting document for that change.

Bora: We accepted all changes and made one minor change for clarity.
Hoeffel: Changes accepted.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


Page 364 of 2169

01682

>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 10:33 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)
Subject: Stipulations
Gents,

Attached are the below stipulations, Round We have not finalized
Hoskins, but will first thing tomorrow morning.

White- all accepted.

Thian- all accepted. Once it gets signed by the defense tomorrow, we will
immediately send to for final review by Ms. Thian.

Bora- edits tracked.
Hoeffel- edits tracked.
Nehring - all accepted.

Scott- all accepted, except last addition. This was a SOUTHCOM issue not
CENTCOM.

Woods- all accepted with an addition.
Van all accepted, and then edits based on our conversation with her
this afternoon. After reading the stipulation to Ms. Van she

corrected the portions that we added with more clarity.

v/r
Ashden

Page 365 of 2169

01683

From: Fein, Ashden MAJ USARMY MDW (US)
To: rl Th MA ARMY Tooman, (Joshua USARMY David (329mm
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Wh te Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Bcc: von Elten, Alexander (Alec) CPT USARMY (US)
Subject: RE: Stips

Date: Monday, June 10, 2013 7:43:00 AM

MAJ Hurley,

I spoke to his SJ A last night and he should be coordinating this phone meeting starting this morning.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Monday, June 10, 2013 7:14 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

Some help would be great. I have no problem cold calling RADL Woods, but I think my identity and relationship to
this case would have to be verified by someone.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 10, 2013 2:35 AM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips
MAJ Hurley,

I know I just sent the Stip back to you for review. If you would like us to assist with setting up a phone call, we will
start first thing tomorrow morning.

Page 366 of 2169

01684

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 6:31 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

One stip we haven't said much about is RADL Woods. I would like to have him validate the stipulation and
describe - in greater detail - his process of review. Do you have a good phone number for his aide? I anticipate that
this will take a couple of days to knock out through email or a phone call.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:50 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Hurley,
That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

Page 367 of 2169

01685

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY (US)

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 09, 2013 12:30 PM
To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Page 368 of 2169

01686

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Ashden,

Page 369 of 2169

01687

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 370 of 2169

01688

Page 371 of 2169

01689

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW PT ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: RE: Stips
Date: Monday, June 10, 2013 7:13:44 AM
MAJ Fein

Some help would be great. I have no problem cold calling RADL Woods, but I think my identity and relationship to
this case would have to be verified by someone.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, June 10, 2013 2:35 AM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Hurley,

I know I just sent the Stip back to you for review. If you would like us to assist with setting up a phone call, we will
start first thing tomorrow morning.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 6:31 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

One stip we haven't said much about is RADL Woods. I would like to have him validate the stipulation and

Page 372 of 2169

01690

describe - in greater detail - his process of review. Do you have a good phone number for his aide? I anticipate that
this will take a couple of days to knock out through email or a phone call.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:50 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Hurley,
That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Fein

Here are the changes for Nehring. Is there a way that we can reView all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 09, 2013 9:12 PM

Page 373 of 2169

01691

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)
Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY (US)

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Page 374 of 2169

01692

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





Page 375 of 2169

01693

>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available Via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to reView and let us know if there are issues.

Also, after reViewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 376 of 2169

01694



From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas MAJ USARMY Tooman, (Joshua ,1 QPT USARMY
.05).

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stipulations

Date: Monday, June 10, 2013 6:59:36 AM

Attachments: 130609 of Expected Testimony (WoodsD).docx
WM
130609 of Expected Testimony (BoraW).docx

Ashden,

I am verifying the changes you made on Ms. stipulation. Once
I hear back from her, I will let you know. With regards to the other
changes we will do the following:

Woods: I have attached an additional change based upon your addition. I
have also attached the supporting document for that change.

Bora: We accepted all changes and made one minor change for clarity.

Hoeffel: Changes accepted.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 10:33 PM
To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT

USARMY (US)

Cc:

USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stipulations

Page 377 of 2169

Gents,

Attached are the below stipulations, Round We have not finalized
Hoskins, but will first thing tomorrow morning.

White- all accepted.

Thian- all accepted. Once it gets signed by the defense tomorrow, we will
immediately send to for final reView by Ms. Thian.

Bora- edits tracked.
Hoeffel- edits tracked.
Nehring - all accepted.

Scott- all accepted, except last addition. This was a SOUTHCOM issue not
CENTCOM.

Woods- all accepted with an addition.
Van all accepted, and then edits based on our conversation with her
this afternoon. After reading the stipulation to Ms. Van she

corrected the portions that we added with more clarity.

V/r
Ashden

Page 378 of 2169

01695

01696

From: Fein Ashden MAJ USARMY MDW US
To: Th MA ARMY Tooman, (Joshua ,1 QPT USARMY David gagmbg
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us ;?_c_xusmw us





Bcc:

Subject: RE: Stips

Date: Sunday, June 09,201310:35:00 PM
MAJ Hurley,

I know I just sent the Stip back to you for review. If you would like us to assist with setting up a phone call, we will
start first thing tomorrow morning.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 6:31 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

One stip we haven't said much about is RADL Woods. I would like to have him validate the stipulation and
describe - in greater detail - his process of review. Do you have a good phone number for his aide? I anticipate that
this will take a couple of days to knock out through email or a phone call.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:50 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Hurley,

Page 379 of 2169

01697

That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Fein

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Sir

Page 380 of 2169

01698

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

Page 381 of 2169

01699

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)
Subject: Stips
Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

Page 382 of 2169

01700

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 383 of 2169

01701

From: Fein, Ashden MAJ USARMY MDW (US)
To: David mgmpe; r Th FMA ARMY ;TQQman, ,(gehue
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stipulations
Date: Sunday, June 09,201310:32:00 PM

Attachments: 130609 of Expected Testimony (WhiteF).docx
130609 of Expected Testimony (WoodsD).docx
130609 of Expected Testimony (VanAIstyneD).docx
130609 of Expected Testimony (NehringM).docx
130609 1931 -Sti ulation of Ex ected Testimon ThianT .docx
130609 of Expected Testimony (ScottJ).docx
130609 of Expected Testimony (BoraW).docx
130609 of Expected Testimony (HoeffeIP).docx





Gents,

Attached are the below stipulations, Round We have not finalized Hoskins, but will first thing tomorrow
morning.

White- all accepted.

Thian- all accepted. Once it gets signed by the defense tomorrow, we will immediately send to for final reView
by Ms. Thian.

Bora- edits tracked.

Hoeffel- edits tracked.

Nehring - all accepted.

Scott- all accepted, except last addition. This was a SOUTHCOM issue not CENTCOM.
Woods- all accepted with an addition.

Van all accepted, and then edits based on our conversation with her this afternoon. After reading the
stipulation to Ms. Van she corrected the portions that we added with more clarity.

V/r
Ashden

Page 384 of 2169

01702

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW PT ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: RE: Stips
Date: Sunday, June 09, 2013 6:31:17 PM
MAJ Fein

One stip we haven't said much about is RADL Woods. I would like to have him validate the stipulation and
describe - in greater detail - his process of review. Do you have a good phone number for his aide? I anticipate that
this will take a couple of days to knock out through email or a phone call.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:50 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

MAJ Hurley,
That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

MAJ Fein

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading

Page 385 of 2169

01703

comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY (US)

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Page 386 of 2169

01704

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Page 387 of 2169

01705

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 388 of 2169

01706

From: Fein Ashden MAJ USARMY MDW US
To: r Th MA ARMY Tooman, (Joshua ,1 QPT USARMY David
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: RE: Stips
Date: Sunday, June 09, 2013 5:50:00 PM
MAJ Hurley,

That sounds like a good plan that we can work out tomorrow.
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Sunday, June 09, 2013 5:46 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY David Coombs

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

MAJ Fein

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents while everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY wsx? USARMY wsx? USARMY

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!

Page 389 of 2169

01707



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY (US)

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Sunday, June 09, 2013 12:27 PM

Page 390 of 2169

01708

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)
Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com




>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM
To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Page 391 of 2169

01709

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 392 of 2169

01710

From: Hurley, Thomas MAJ USARMY (US)
To: in A MA ARMY MDW PT ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: RE: Stips

Date: Sunday, June 09, 2013 5:46:11 PM
Attachments: Nehring - Defense Changesdocx
MAJ Fein

Here are the changes for Nehring. Is there a way that we can review all of the material (including the PEs) over
lunch in order to avoid thumbing through hundreds of documents While everyone stares at us? My reading
comprehension plummets under those conditions.

Thanks.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 9:12 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Gents,
We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Sir

Page 393 of 2169

01711

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden

Page 394 of 2169

01712



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com





>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Page 395 of 2169

01713

Also, after reviewing the remainder of the Witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 396 of 2169

01714

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman, Joshua ,1 (PT USARMY David gagmbg; Th MA ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us ;?_c_xusmw us





Bcc:

Subject: RE: Stips

Date: Sunday, June 09, 2013 5:12:00 PM
Gents,

We also sent Grant and did not hear back.

Overall, you should still be getting back to us on Grant, Nehring, and Hoskins.\
Thanks!



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY (US)

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,

Page 397 of 2169

01715

Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508) 689-9282

Page 398 of 2169

01716

coombs armycourtmartialdefense.com




>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available Via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to reView and let us know if there are issues.

Also, after reViewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 399 of 2169

01717

From: Fein, Ashden MAJ USARMY MDW (US)
To: Tooman, Joshua ,1 (PT USARMY David gnombg; Th MA ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us ;?_c_xusmw us



Bcc:
Subject: RE: Stips
Date: Sunday, June 09, 2013 4:22:00 PM

Attachments: 130609 of Exoected Testimony (NehringM).docx



Gents,
Attached is the Stip for Nehring. We will review the proposed edits today and have our next round by COB today.

v/r
Ashden



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 3:01 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY USARMY (US)

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Page 400 of 2169

01718

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Page 401 of 2169

01719

Fax: (508) 689-9282
coombs armycourtmartialdefense.com




>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available Via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to reView and let us know if there are issues.

Also, after reViewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 402 of 2169

01720

From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ USARMY
.05).

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: Re: Stips
Date: Sunday, June 09, 2013 3:01 :49 PM
Thanks.

From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 03:00 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs Hurley,
Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Page 403 of 2169

01721

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com




Page 404 of 2169

01722

>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available Via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to reView and let us know if there are issues.

Also, after reViewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 405 of 2169

01723

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW r Th FMA ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us

Subject: RE: Stips
Date: Sunday, June 09, 2013 3:00:40 PM
Attachments: Woods Stio.docx

White Stigdocx
Thian Stigdocx
mm

Bora Stio.docx
Artale Stios.docx



Sir

Attached are seven stips for which we request some modifications. We'll bring the other, signed copies over shortly.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Tooman, Joshua CPT USARMY David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.

Page 406 of 2169

01724



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com




>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is

Page 407 of 2169

01725



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 408 of 2169

01726

From: Fein, Ashden MAJ USARMY MDW (US)
To: Tooman, (Joshua ,1 (PT USARMY David gagmbg; Th MA ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: RE: Stips

Date: Sunday, June 09, 2013 12:30:00 PM
Thanks.



From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, June 09, 2013 12:30 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips

Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

Page 409 of 2169

01727

Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com



>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 410 of2169

01728

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW r Th FMA ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Subject: RE: Stips
Date: Sunday, June 09, 2013 12:30:00 PM
Sir

We'll get you our changes to the others shortly for your review. We'll discuss the additional names and let you
know this afternoon.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 09, 2013 12:27 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY wsx? USARMY am

Subject: RE: Stips

David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY wsx? USARMY wsx? USARMY

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.
Law Office of David E. Coombs

Page 411 of2169

01729

11 South Angell Street, #317

Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com



>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 412 of2169

01730

From: Fein, Ashden MAJ USARMY MDW (US)
To: "David gagmbs"; Th MA ARMY PT ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us ;?_c_xusmw us





Bcc:

Subject: RE: Stips

Date: Sunday, June 09, 2013 12:27:00 PM
David,

Thank you. We will review and send back. Are you still reviewing the remainder or are those fine? Also what
about the others that we added below?

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 09, 2013 8:52 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY USARMY

Subject: RE: Stips
Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Page 413 of2169

01731

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Also, after reviewing the remainder of the witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

v/r
Ashden

Page 414 of2169

01732

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas LJSARMY Tooman, (Joshua ,1 QPT LJSARMY


Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us ;?_c_xusmw us
Subject: RE: Stips
Date: Sunday, June 09, 2013 8:52:24 AM
Attachments: 130608 of Expected Testimony (VanAIstyneD).docx



Ashden,

Here are the changes for Debra Van Let me know if you have issues.
If not, we will have this signed and sent to you this afternoon.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 08, 2013 8:03 PM

To: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY (US)

Subject: Stips

Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others
and make classified ones available via a classified laptop, so that you can

track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you
to review and let us know if there are issues.

Page 415 of2169

01733

Also, after reviewing the remainder of the Witnesses, is the defense willing
to stipulate to Glenn, Wisecarver, ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 416 of2169

From:
To:

Cc:

Bcc:

Subject:
Date:
Attachments:

01734


David Hurley, Thomas MAJ LJSARMY TQQman, (Joshua
PT ARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
us us



Stips

Saturday, June 08, 2013 8:03:00 PM

130608 of Expected Testimony (EIIisK).docx
130608 of Expected Testimony (ManderM).docx
130608 of Expected Testimony (SchasteenD).docx
130608 of Expected Testimony (ScottJ).docx
130608 of Expected Testimony (ThianT).docx
130608 of Expected Testimony (VanAIstyneD).docx
130608 of Expected Testimony (WhiteF).docx
130608 of Expected Testimony (WoodsD).docx
130608 of Expected Testimony (BoraW).docx
130608 of Expected Testimony (HoeffelP).docx
130608 of Expected Testimony (RockR).docx
130608 of Expected Testimony (ArtaleP).docx



Gents,

Attached are 12 stipulations. Tomorrow early afternoon we will send others and make classified ones available Via
a classified laptop, so that you can track changes, if needed.

We did not fill in PE numbers on here yet, because it would be best for you to reView and let us know if there are

issues.

Also, after reviewing the remainder of the witnesses, is the defense willing to stipulate to Glenn, Wisecarver,
ohnsonG, and Larue?

Thanks!

V/r
Ashden

Page 417 of2169

01735

From: Fein Ashden MAJ USARMY MDW (US)

To: Tooman, (Joshua ,1 QPT USARMY David (329mm Hurley, Thomas
MAJ USARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)





Subject: RE: Stips

Date: Saturday, June 08, 2013 11:22:00 AM
Thank you.



From: Tooman, Joshua CPT USARMY (US)

Sent: Saturday, June 08, 2013 11:06 AM

To: Fein, Ashden MAJ USARMY MDW David Coombs Hurley,
Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

Sir

A couple things on Artale:

1. The title of the document ends with a question mark, not a period. Thus, any reference to the document should
re?ect the inquisitive nature of the document's title. That is, "Wikileaks.org-An Online Reference to Foreign

Intelligence Services, Insurgents, or Terrorist Groups

2. Please add that the logs do not indicate whether the user actually viewed the .pdf or Word file. Likewise, the
logs do not indicate whether the document was printed or saved, nor do they indicate how long an individual
looked at the document, if at all.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, June 07, 2013 7:52 PM

To: David Coombs Hurley, Thomas MAJ USARMY Tooman,
Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,
The following stips are attached:

1. Buchanan. Made the requested changes. We did not track changes for the "neutral" search because it would be a
mess. We highlighted the account creation time for you to review.

2. Artale.

Page 418 of2169

01736

3. Chamberlin.

4. Grant.

5 . Wilbur.

More to follow tomorrow.

V/r
Ashden

Page 419 of2169

01737

From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW David Hurley, Thomas
USARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stips

Date: Saturday, June 08, 2013 11:06:31 AM
Sir

A couple things on Artale:

1. The title of the document ends with a question mark, not a period. Thus, any reference to the document should
re?ect the inquisitive nature of the document's title. That is, "Wikileaks.org-An Online Reference to Foreign
Intelligence Services, Insurgents, or Terrorist Groups

2. Please add that the logs do not indicate whether the user actually viewed the .pdf or Word file. Likewise, the
logs do not indicate whether the document was printed or saved, nor do they indicate how long an individual
looked at the document, if at all.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, June 07, 2013 7:52 PM

To: David Coombs Hurley, Thomas MAJ USARMY Tooman,
Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips
Gents,

The following stips are attached:

1. Buchanan. Made the requested changes. We did not track changes for the "neutral" search because it would be a
mess. We highlighted the account creation time for you to review.

2. Artale.

3. Chamberlin.

4. Grant.

5. Wilbur.

More to follow tomorrow.

v/r
Ashden

Page 420 of 2169

01738

From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW David Hurley, Thomas


Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

Date: Saturday, June 08,2013 9:56:29 AM



Got 'em, sir. We'll take a look. Thanks.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, June 07, 2013 7:52 PM

To: David Coombs Hurley, Thomas MAJ USARMY Tooman,
Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips
Gents,

The following stips are attached:

1. Buchanan. Made the requested changes. We did not track changes for the "neutral" search because it would be a
mess. We highlighted the account creation time for you to review.

2. Artale.

3. Chamberlin.

4. Grant.

5. Wilbur.

More to follow tomorrow.

V/r
Ashden

Page 421 of 2169

From:
To:

Cc:

Bcc:

Subject:
Date:
Attachments:

01739

Fein, Ashden MAJ USARMY MDW (US)
David r Th MA ARMY mm

PT ARMY
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Stips

Friday, June 07,2013 7:52:00 PM

130607 of Exgected Testimony (GrantJ).docx
130607 of Exgected Testimony (WilburJ).docx
130607 of Exgected Testimony (BuchananS).docx
130607 of Exgected Testimony (ChamberlinS).docx
130607 of Exgected Testimony (ArtaleP).docx





Gents,

The following stips are attached:

1. Buchanan. Made the requested changes. We did not track changes for the "neutral" search because it would be a
mess. We highlighted the account creation time for you to review.

2. Artale.

3. Chamberlin.

4. Grant.

5 . Wilbur.

More to follow tomorrow.

V/r
Ashden

Page 422 of 2169

01740



From: David Coombs

To: Fein. Ashden MAJ USARMY MDW (US): Hurlev. Thomas MAJ USARMY (US): TQQman ,Jgshua ,1 QPT LJSARMY
.051

Cc: USARMY (US): Mitroka. Katherine CPT USARMY (US): Morrow. JoDean (Joe) CPT



USARMY USAMDW (US): Overqaard. Anqel CPT USARMY (US): von Elten. Alexander (Alec) CPT USARMY
(US): Whvte. Hunter CPT USARMY (US): USARMY (US)



Subject: RE: stips
Date: Friday, June 07,201312:34:12 PM
Ashden,

We will sign and return to you at 1400.

Best,
David

-- Original message

From: "Fein, Ashden MAJ USARMY MDW

Date: 06/07/2013 12:08 PM (GMT-05 :00)

To: "David Coombs

Thomas MAJ USARMY ?,"T00man, Joshua CPT USARMY

>,"Mitr0ka, Katherine CPT
,"Morrow, 0Dean (Joe) CPT USARMY USAMDW
,"Overgaard, Angel CPT USARMY

on Elten, Alexander (Alec) CPT USARMY

"Whyte, Hunter CPT USARMY

USARMY














. USARMY
USARMY

Gents,

Withers and Fung attached. We accepted all changes with no additions. Bettencourt is also attached.

V/r
Ashden

Page 423 of 2169

01741






From: Fein, Ashden MAJ USARMY MDW (US)
To: David Hurley, Thomas MAJ LJSARMY TQQman, (Joshua
PT ARMY

Cc: USARMY Mitroka, Katherine CPT USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Overgaard, Angel CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Whyte, Hunter CPT USARMY USARMY (US)

Bcc:

Subject: stips

Date: Friday, June 07,2013 12:08:00 PM

Attachments: 130607 of Exgected Testimony (WithersA).docx
130607 of Exgected Testimony (FungJ).docx
130607 of Exgected Testimony (BettencourtT).docx

Gents,

Withers and Fung attached. We accepted all changes with no additions. Bettencourt is also attached.

V/r
Ashden

Page 424 of 2169

01742

From: Fein, Ashden MAJ USARMY MDW (US)

To: "Hrl FMA

Cc: David Coombs Tooman, Joshua CPT USARMY (US)
Subject: RE: Fung and Withers Stipulations

Date: Friday, June 07,2013 10:05:00 AM



Thank you. We will start looking at these ASAP. And send more as we
complete.



From: Hurley, Thomas MAJ OSD OMC Defense
Sent: Friday, June 07, 2013 8:36 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: David Coombs Tooman, Joshua CPT
USARMY (US)

Subject: Fung and Withers Stipulations

MAJ Fein

Attached please find the Fung and Withers stips that include some changes
(noted in track changes). Sorry this took longer than we expected. We have
no changes to the McManus stip. The Yun stip is going to take a while, but

we should have those changes to you by mid-afternoon.

V/r
MAJ Hurley

Page 425 of 2169

01743

From: Hurley, Thomas MAJ OSD OMC Defense

To: in A MA ARMY MDW

Cc: David Coombs Tooman, Joshua CPT USARMY (US)
Subject: Fung and Withers Stipulations

Date: Friday, June 07,2013 8:38:05 AM

Attachments: 130605-Stipulation of Exgected Testimony (FungJ).docx
130605-Stipulation of Exgected Testimony (WithersA).docx



MAJ Fein
Attached please find the Fung and Withers stips that include some changes (noted in track changes). Sorry this took
longer than we expected. We have no changes to the McManus stip. The Yun stip is going to take a while, but we

should have those changes to you by mid-afternoon.

V/r
MAJ Hurley

Page 426 of 2169

01744

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas USARMY Tooman, ,(gehue QPT USARMY
ALE)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stip
Date: Thursday, June 06, 2013 8:05:44 PM
Ashden,

Good to hear that you are moving forward with all the stips. I am really
hoping that we can give COL Lind at least 30 or so on Monday to show her
that we were productive over the break. We will return the stips that you
sent to us either signed or with comments tomorrow.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 7:40 PM

To: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Re: Stip
David, we are moving forward with all stips. I will send each one as we
finish them. State stips were the exception so that we can ensure both

parties are on the same sheet.

Vr
Ashden

Original Message

Page 427 of 2169

01745

From: David Coombs [mailtozcoombs armycourtmartialdefense.com]
Sent: Thursday, June 06, 2013 11:21 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc:? USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip
Ashden,

I understood the plan on the DOS witnesses, I was asking about the non-DOS
witnesses. I would like to knock out as many of these as possible over the
next three days so that we are not in a situation where we are holding up

the trial at a later date.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 6:35 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip

David,

As I get them, I will send them. I do expect many more over the next 2
days. We are holding on the rest of the DOS Stips until you get back to me

on PDAS Yun's.

v/r
Ashden

Page 428 of 2169

01746



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Thursday, June 06, 2013 6:28 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip
Ashden,

Thank you. We will go over these tomorrow with PFC and run them to you
once they are signed. Do you expect to have more tomorrow?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:52 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip

Gents. Please use the attached Stip. It has the updated PE numbers
included - 61 and 62.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:50 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT

Page 429 of 2169

01747

USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)
Subject: Stip

Gents,

The stip for Mr. Buchanan is attached.
Thus far, you should have the following:
Mr. Fung

Mr. Withers

Mr. McManus

Mr. Buchanan

PDAS Yun (classified)

Thanks!

V/r
MAJ Fein

Page 430 of 2169

01748

From: Fein Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ USARMY Tooman, (Joshua ,1 QPT USARMY


Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)



Bcc:
CPT USARMY (US)
Subject: Re: Stip
Date: Thursday, June 06, 2013 7:39:59 PM



David, we are moving forward with all stips. I will send each one as we finish them. State stips were the exception
so that we can ensure both parties are on the same sheet.

Vr
Ashden

Original Message

From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Thursday, June 06, 2013 11:21 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stip

Ashden,

I understood the plan on the DOS witnesses, I was asking about the non-DOS
witnesses. I would like to knock out as many of these as possible over the
next three days so that we are not in a situation where we are holding up

the trial at a later date.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is

Page 431 of 2169

01749



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 6:35 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip
David,

As I get them, I will send them. I do expect many more over the next 2
days. We are holding on the rest of the DOS Stips until you get back to me
on PDAS Yun's.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Thursday, June 06, 2013 6:28 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip
Ashden,

Thank you. We will go over these tomorrow with PFC and run them to you
once they are signed. Do you expect to have more tomorrow?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is

Page 432 of 2169

01750



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:52 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip

Gents. Please use the attached Stip. It has the updated PE numbers
included - 61 and 62.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:50 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stip

Gents,

The stip for Mr. Buchanan is attached.
Thus far, you should have the following:
Mr. Fung

Mr. Withers

Mr. McManus

Mr. Buchanan

PDAS Yun (classified)

Thanks!

V/r
MAJ Fein

Page 433 of 2169

01751

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas USARMY Tooman, ,(gehue ,1ng USARMY
ALE)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stip
Date: Thursday, June 06, 2013 7:21:27 PM
Ashden,

I understood the plan on the DOS witnesses, I was asking about the non-DOS
witnesses. I would like to knock out as many of these as possible over the
next three days so that we are not in a situation where we are holding up

the trial at a later date.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 6:35 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip

David,

As I get them, I will send them. I do expect many more over the next 2
days. We are holding on the rest of the DOS Stips until you get back to me

on PDAS Yun's.

v/r
Ashden

Page 434 of 2169

01752



From: David Coombs [m il rm i m]

Sent: Thursday, June 06, 2013 6:28 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip
Ashden,

Thank you. We will go over these tomorrow with PFC and run them to you
once they are signed. Do you expect to have more tomorrow?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:52 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip

Gents. Please use the attached Stip. It has the updated PE numbers
included - 61 and 62.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:50 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT

Page 435 of 2169

01753

USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)
Subject: Stip

Gents,

The stip for Mr. Buchanan is attached.
Thus far, you should have the following:
Mr. Fung

Mr. Withers

Mr. McManus

Mr. Buchanan

PDAS Yun (classified)

Thanks!

V/r
MAJ Fein

Page 436 of 2169

01754

From: Fein, Ashden MAJ USARMY MDW (US)
To: "David Th MA ARMY PT ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)





Subject: RE: Stip
Date: Thursday, June 06, 2013 6:34:00 PM
David,

As I get them, I will send them. I do expect many more over the next 2 days. We are holding on the rest of the
DOS Stips until you get back to me on PDAS Yun's.

v/r
Ashden



From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Thursday, June 06, 2013 6:28 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)
Subject: RE: Stip

Ashden,

Thank you. We will go over these tomorrow with PFC and run them to you
once they are signed. Do you expect to have more tomorrow?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



Page 437 of 2169

01755

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:52 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip

Gents. Please use the attached Stip. It has the updated PE numbers
included - 61 and 62.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:50 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stip

Gents,

The stip for Mr. Buchanan is attached.
Thus far, you should have the following:
Mr. Fung

Mr. Withers

Mr. McManus

Mr. Buchanan

PDAS Yun (classified)

Thanks!

V/r
MAJ Fein

Page 438 of 2169

01756

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas USARMY Tooman, ,(gehue ,1ng USARMY
.051

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stip
Date: Thursday, June 06. 2013 6:28:10 PM
Ashden,

Thank you. We will go over these tomorrow with PFC and run them to you
once they are signed. Do you expect to have more tomorrow?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:52 PM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stip

Gents. Please use the attached Stip. It has the updated PE numbers
included - 61 and 62.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:50 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

Page 439 of 2169

01757

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine
CPT USARMY USARMY (US)
Subject: Stip

Gents,

The stip for Mr. Buchanan is attached.

Thus far, you should have the following:

Mr. Fung

Mr. Withers

Mr. McManus

Mr. Buchanan

PDAS Yun (classified)

Thanks!

V/r
MAJ Fein

Page 440 of 2169

01758

From: Fein Ashden MAJ USARMY MDW (US)

To: Fein Ashden MA) MDW David Hurley Thomas MA) TQQman ,(ggmta
QPT

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)

Subject: RE: Stip
Date: Thursday, June 06, 2013 4:51:00 PM
Attachments: 130606-Stioulation of Exoected Testimony (BuchananS) uodatedoocx





Gents. Please use the attached Stip. It has the updated PE numbers included - 61 and 62.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 4:50 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stip

Gents,

The stip for Mr. Buchanan is attached.
Thus far, you should have the following:
Mr. Fung

Mr. Withers

Mr. McManus

Mr. Buchanan

PDAS Yun (classified)

Thanks!

V/r
MAJ Fein

Page 441 of 2169

01759

From: Fein, Ashden MAJ USARMY MDW (US)
To: David mgmpe; r Th FMA ARMY ;TQQman, ,(gehue
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stip
Date: Thursday, June 06, 2013 4:49:00 PM

Attachments: 130606-Stioulation of Exoected Testimony (BuchananS).docx



Gents,

The stip for Mr. Buchanan is attached.
Thus far, you should have the following:
Mr. Fung

Mr. Withers

Mr. McManus

Mr. Buchanan

PDAS Yun (classified)

Thanks!

V/r
MAJ Fein

Page 442 of 2169

01760



From: Hurley, Thomas MAJ USARMY (US)

To: in A MA ARMY MDW

Cc: USARMY USARMY USAMDW Morrow, JoDean (Joe) CPT


Subject: RE: Yun Stip

Date: Thursday, June 06, 2013 1:18:29 PM

MAJ Fein

I acknowledge receipt of the stipulation for Mr. Yun.

V/r





From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, June 06, 2013 5:12 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc:? USARMY USARMY USAMDW Morrow, JoDean
(Joe) CPT USARMY USAMDW (US)

Subject: Yun Stip

MAJ Hurley,

The purpose of this email is to account for me hand delivering a copy today of our proposed stipulation of expected
testimony for Yun that is classified secret noforn.

Thanks.

V/r
MAJ Fein

Page 443 of 2169

01761



From: Fein, Ashden MAJ USARMY MDW (US)

To: r Th MA ARMY

Cc: USARMY USARMY USAMDW Morrow, JoDean (Joe) CPT
USARMY USAMDW (US)

Subject: Yun Stip

Date: Thursday, June 06, 2013 1:12:00 PM

MAJ Hurley,

The purpose of this email is to account for me hand delivering a copy today of our proposed stipulation of expected
testimony for Yun that is classified secret noforn.

Thanks.

V/r
MAJ Fein

Page 444 of 2169

01762



From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW David Hurley, Thomas MA) USARMY
- USARMY (us)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Email

Date: Wednesday, June 05,201312:40:20 PM

Thanks, sir.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, June 05, 2013 9:03 AM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY -
USARMY (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,

Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY (US)

Subject: Email

Defense,
All members of the prosecution deleted both emails from our computer systems Without reading them.

V/r
MAJ Fein

Page 445 of 2169

01763





From: Fein, Ashden MAJ USARMY MDW (US)

To: David Th MA ARMY TQQman Joshua ,1ng LJSARMY
- LJSARMY (us)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
?_c_tusmw us

Subject: Email

Date: Wednesday, June 05,2013 9:03:00 AM

Defense,

All members of the prosecution deleted both emails from our computer systems Without reading them.

V/r
MAJ Fein

Page 446 of 2169

01764

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman ,(gemta David Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka Katherine CPT USARMY USARMY (US)





Subject: RE: Stips
Date: Wednesday, June 05,2013 7:28:00 AM
Josh,

We are deleting our emails. David just replied to your email and we are not reading that one either. I will confirm
when the entire team deleted your email and David's email.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, June 05, 2013 7:05 AM

To: Fein, Ashden MAJ USARMY MDW David Coombs; Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stips

All

I sent an reply to this email that was intended for the Defense team only. I'd ask that if you have not read it, please
delete it.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, June 04, 2013 11:19 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,
Attached are the first two stips in the Katz hard drive chain of custody. The third is ready and we just have to verify

the serial numbers and hash value. We also have the Steve Buchanan stip completed, and although its unclassified,
its on SIPR. We should have burning capability tomorrow to move it from SIPR to NIPR. Finally, I will review

Page 447 of 2169

01765

the Yun stipulation tomorrow at lunch and be able to give that to you for review.

V/r
Ashden

Page 448 of 2169

01766

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW ;David r Th FMA ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)



Subject: RE: Stips
Date: Wednesday, June 05,2013 7:04:41 AM
All

I sent an reply to this email that was intended for the Defense team only. I'd ask that if you have not read it, please
delete it.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, June 04, 2013 11:19 PM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Gents,

Attached are the first two stips in the Katz hard drive chain of custody. The third is ready and we just have to verify
the serial numbers and hash value. We also have the Steve Buchanan stip completed, and although its unclassified,
its on SIPR. We should have burning capability tomorrow to move it from SIPR to NIPR. Finally, I will review

the Yun stipulation tomorrow at lunch and be able to give that to you for review.

v/r
Ashden

Page 449 of 2169

01767





From: Fein, Ashden MAJ USARMY MDW (US)

To: "David r Th MA ARMY PT ARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: Stips

Date: Tuesday, June 04, 2013 11:19:00 PM

Attachments: 130604-Stipulation of Expected Testimony (WithersA).docx
130604-Stipulation of Expected Testimony (FungJ).docx

Gents,

Attached are the first two stips in the Katz hard drive chain of custody. The third is ready and we just have to verify
the serial numbers and hash value. We also have the Steve Buchanan stip completed, and although its unclassified,
its on SIPR. We should have burning capability tomorrow to move it from SIPR to NIPR. Finally, I will review
the Yun stipulation tomorrow at lunch and be able to give that to you for review.

v/r
Ashden

Page 450 of 2169

01768

From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ USARMY Tooman, (Joshua ,1 QPT USARMY


Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)



CPT USARMY (US)
Subject: Re: Government Filings, etc.
Date: Sunday, June 02, 2013 5:13:00 PM



Thank you.

Original Message

From: David Coombs [m il rm i m]

Sent: Sunday, June 02, 2013 09:08 PM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY USARMY (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY
Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine
CPT USARMY USARMY (US)

Subject: RE: Government Filings, etc.

Ashden,

Not a problem. Whatever way is easier for you we can do on the
stipulations. Just print up a new version, and we will have it signed
tomorrow.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 02, 2013 11:18 AM
To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT

Page 451 of2169

01769

USARMY USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

David,
Thank you. We will review this today.

Attached are the following stipulations of expected testimony: Edwards,
Clapper, Mairena, Robertson, and Young. We did a final review of the
physical evidence and realized that we transcribed a serial number
incorrectly into the authentication stipulations. Unfortunately, we need to
update these to re?ect the serial number confusion. Also, you will see for
Edwards and Robertson, we added two lines that has them identify the
evidence as for All changes are tracked.

For Robertson, I attached a separate stipulation that accounts for the
identifying of the RES, in case you do not want to re-execute the main
stipulation. I used the version Josh sent Thursday, 30 May 2013 at 1810
hours.

We have the physical evidence on-site starting today, and can make it
available for you to confirm the PE for ID markings and authenticity, if
needed.

Thank you!

V/r
Ashden



From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Sunday, June 02, 2013 8:20 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

Ashden,
I have reviewed the document and made changes by either highlighting the
change or by using track changes for information that I deleted from the

original. Let me know if you have any issues.

Best,
David

David E. Coombs, Esq.
Law Office of David E. Coombs

Page 452 of 2169

01770

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 11:59 PM

To: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

Defense,

Attached is the combined judicial notice. Please let us know Whether there
are any discrepancies.

V/r
MAJ Fein



From: Lind, Denise COL USARMY (US)

Sent: Saturday, June 01, 2013 1:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY
USARMY USARMY Ft McNair Mailbox MDW Court Reporters
USARMY ms)

Katrina MSG USARMY (US)
Subject: Re: Government Filings, etc.

Received. Thank you. Please have hard copy of all for the Court Monday
morning.


Original Message

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 04:59 PM

To: Lind, Denise COL USARMY (US)

Cc: David Coombs Hurley, Thomas MAJ

Page 453 of 2169

01771

USARMY Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander

(Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY Ft McNair Mailbox MDW Court Reporters
USARMY




USARMY (US)
Subject: Government Filings, etc.

Ma'am,
Attached to this email are the following:
1. Completed Stipulation of Expected Testimony of SA Calder Robertson.

2. Based on the continuing obligation under Section and ongoing witness
interviews, the United States submits it's updated Section disclosures.

3. A third party filing for the Court. This filing was served in-person
yesterday on the OSJ A, MDW for the Court. A separate filing was also served
on the Trial Counsel. The Government does not intend to file this third

party filing on behalf of this organization.

4. Combined judicial notice list. The Court asked the parties to compile a
combined judicial notice listing prior to trial. The United States is
finalizing the document to pass to the defense this afternoon. We have
included defense requested judicial notice as well.

5. As for the witness order for the first 25 witnesses, the United States
intends to call SA Smith first then SA Graham, which is a change from the

previously filed order.

v/r
MAJ Fein

Page 454 of 2169

01772



From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas MAJ USARMY Tooman, (Joshua ,1 USARMY


Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Government Filings, etc.

Date: Sunday, June 02,2013 5:08:55 PM

Ashden,

Not a problem. Whatever way is easier for you we can do on the
stipulations. Just print up a new version, and we will have it signed
tomorrow.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, June 02, 2013 11:18 AM

To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY USARMY (US)

Cc: Morrow, ODean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

David,

Thank you. We will review this today.

Attached are the following stipulations of expected testimony: Edwards,
Clapper, Mairena, Robertson, and Young. We did a final review of the
physical evidence and realized that we transcribed a serial number

incorrectly into the authentication stipulations. Unfortunately, we need to
update these to re?ect the serial number confusion. Also, you will see for

Page 455 of 2169

01773

Edwards and Robertson, we added two lines that has them identify the
evidence as for All changes are tracked.

For Robertson, I attached a separate stipulation that accounts for the
identifying of the RES, in case you do not want to re-execute the main
stipulation. I used the version Josh sent Thursday, 30 May 2013 at 1810
hours.

We have the physical evidence on-site starting today, and can make it
available for you to confirm the PE for ID markings and authenticity, if
needed.

Thank you!

V/r
Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, June 02, 2013 8:20 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

Ashden,

I have reviewed the document and made changes by either highlighting the
change or by using track changes for information that I deleted from the
original. Let me know if you have any issues.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



Page 456 of 2169

01774

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 11:59 PM

To: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

Defense,

Attached is the combined judicial notice. Please let us know whether there
are any discrepancies.

V/r
MAJ Fein



From: Lind, Denise COL USARMY (US)

Sent: Saturday, June 01, 2013 1:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY Ft McNair Mailbox MDW Court Reporters

USARMY ms)-
USARMY (US)

Subject: Re: Government Filings, etc.

Received. Thank you. Please have hard copy of all for the Court Monday
morning.


Original Message

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 04:59 PM

To: Lind, Denise COL USARMY (US)

Cc: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander

(Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY USARMY Ft McNair Mailbox MDW Court Reporters
USARMY





USARMY (US)
Subject: Government Filings, etc.

Ma'am,
Attached to this email are the following:
1. Completed Stipulation of Expected Testimony of SA Calder Robertson.

2. Based on the continuing obligation under Section and ongoing witness

Page 457 of 2169

01775

interviews, the United States submits it's updated Section disclosures.

3. A third party filing for the Court. This filing was served in-person
yesterday on the OSJ A, MDW for the Court. A separate filing was also served
on the Trial Counsel. The Government does not intend to file this third

party filing on behalf of this organization.

4. Combined judicial notice list. The Court asked the parties to compile a
combined judicial notice listing prior to trial. The United States is
finalizing the document to pass to the defense this afternoon. We have
included defense requested judicial notice as well.

5. As for the witness order for the first 25 witnesses, the United States
intends to call SA Smith first then SA Graham, which is a change from the

previously filed order.

v/r
MAJ Fein

Page 458 of 2169

01776

From: Fein, Ashden MAJ USARMY MDW (US)
To: David rl Th MA ARMY Tooman, ,(gghua QPT USARMY
- USARMY (us)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
?_c_xusmw us

Subject: RE: Government Filings, etc.

Date: Sunday, June 02,201311:17:00 AM

Attachments: 130602-Stipulation of Expected Testimony (ClapperC).docx
130602-Stipulation of Expected Testimony (EdwardsA).docx
130602-Stipulation of Expected Testimony (MairenaT).docx
130602-Stipulation of Expected Testimony (RobertsonC) Final 2-1.docx
130602-Stipulation of Expected Testimony (RobertsonC) ShortAdditional.docx
130602-Stipulation of Expected Testimony (YoungG).docx

Bcc:





David,
Thank you. We will review this today.

Attached are the following stipulations of expected testimony: Edwards, Clapper, Mairena, Robertson, and Young.
We did a final review of the physical evidence and realized that we transcribed a serial number incorrectly into the
authentication stipulations. Unfortunately, we need to update these to re?ect the serial number confusion. Also,
you will see for Edwards and Robertson, we added two lines that has them identify the evidence as for
All changes are tracked.

For Robertson, I attached a separate stipulation that accounts for the identifying 0f the RES, in case you do not want
to re-execute the main stipulation. I used the version Josh sent Thursday, 30 May 2013 at 1810 hours.

We have the physical evidence on-site starting today, and can make it available for you to confirm the PE for ID
markings and authenticity, if needed.

Thank you!

V/r
Ashden



From: David Coombs [mailt0:coombs armycourtmartialdefense.com]

Sent: Sunday, June 02, 2013 8:20 AM

To: Fein, Ashden MAJ USARMY MDW Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY USARMY (US)

Cc: Morrow, ODean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY (US)

Subject: RE: Government Filings, etc.

Ashden,

I have reviewed the document and made changes by either highlighting the
change or by using track changes for information that I deleted from the

original. Let me know if you have any issues.

Best,
David

Page 459 of 2169

01777

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 11:59 PM

To: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

Defense,

Attached is the combined judicial notice. Please let us know Whether there
are any discrepancies.

V/r
MAJ Fein



From: Lind, Denise COL USARMY (US)

Sent: Saturday, June 01, 2013 1:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY
USARMY USARMY Ft McNair Mailbox MDW Court Reporters
USARMY ms)

Katrina MSG USARMY (US)
Subject: Re: Government Filings, etc.

Received. Thank you. Please have hard copy of all for the Court Monday
morning.



Original Message
From: Fein, Ashden MAJ USARMY MDW (US)

Page 460 of 2169

01778

Sent: Saturday, June 01, 2013 04:59 PM

To: Lind, Denise COL USARMY (US)

Cc: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander

(Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY Ft McNair Mailbox MDW Court Reporters
USARMY




USARMY (US)
Subject: Government Filings, etc.

Ma'am,
Attached to this email are the following:
1. Completed Stipulation of Expected Testimony of SA Calder Robertson.

2. Based on the continuing obligation under Section and ongoing witness
interviews, the United States submits it's updated Section disclosures.

3. A third party filing for the Court. This filing was served in-person
yesterday on the OSJ A, MDW for the Court. A separate filing was also served
on the Trial Counsel. The Government does not intend to file this third

party filing on behalf of this organization.

4. Combined judicial notice list. The Court asked the parties to compile a
combined judicial notice listing prior to trial. The United States is
finalizing the document to pass to the defense this afternoon. We have
included defense requested judicial notice as well.

5. As for the witness order for the first 25 witnesses, the United States
intends to call SA Smith first then SA Graham, which is a change from the

previously filed order.

v/r
MAJ Fein

Page 461 of 2169

01779



From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas MAJ USARMY ngman, (lgshua ,1 QPT USARMY


Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Government Filings, etc.

Date: Sunday, June 02,2013 8:20:13 AM

Attachments: 130601 - Combined Judicial Notice Accounting .docx

Ashden,

I have reviewed the document and made changes by either highlighting the
change or by using track changes for information that I deleted from the
original. Let me know if you have any issues.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 11:59 PM

To: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY (US)

Cc: Morrow, ODean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Government Filings, etc.

Defense,

Attached is the combined judicial notice. Please let us know whether there
are any discrepancies.

V/r
MAJ Fein



Page 462 of 2169

01780

From: Lind, Denise COL USARMY (US)

Sent: Saturday, June 01, 2013 1:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY Mitroka, Katherine CPT USARMY

USARMY USARMY Ft McNair Mailbox MDW Court Reporters
USARMY -

USARMY (US)
Subject: Re: Government Filings, etc.

Received. Thank you. Please have hard copy of all for the Court Monday
morning.


Original Message

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 04:59 PM

To: Lind, Denise COL USARMY (US)

Cc: David Coombs Hurley, Thomas MAJ
USARMY Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander

(Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY USARMY Ft McNair Mailbox MDW Court Reporters
USARMY





USARMY (US)
Subject: Government Filings, etc.

Ma'am,
Attached to this email are the following:
1. Completed Stipulation of Expected Testimony of SA Calder Robertson.

2. Based on the continuing obligation under Section and ongoing witness
interviews, the United States submits it's updated Section disclosures.

3. A third party filing for the Court. This filing was served in-person
yesterday on the OSJ A, MDW for the Court. A separate filing was also served
on the Trial Counsel. The Government does not intend to file this third

party filing on behalf of this organization.

4. Combined judicial notice list. The Court asked the parties to compile a
combined judicial notice listing prior to trial. The United States is
finalizing the document to pass to the defense this afternoon. We have
included defense requested judicial notice as well.

5. As for the witness order for the first 25 witnesses, the United States
intends to call SA Smith first then SA Graham, which is a change from the

previously filed order.

v/r
MAJ Fein

Page 463 of 2169

01781





From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ USARMY Tooman, (lgshua ,1 QPT USARMY
451;

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Government Filings, etc.

Date: Saturday, June 01.201311:59:00 PM

Attachments: 130601 - Combined Judicial Notice Accounting .docx

Defense,

Attached is the combined judicial notice. Please let us know whether there are any discrepancies.

V/r
MAJ Fein



From: Lind, Denise COL USARMY (US)

Sent: Saturday, June 01, 2013 1:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander
(Alec) CPT USARMY Mitroka, Katherine CPT USARMY USARMY
USARMY Ft McNair Mailbox MDW Court Reporters

USARMY USARMY (US)

Subject: Re: Government Filings, etc.

Received. Thank you. Please have hard copy of all for the Court Monday morning.


Original Message

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Saturday, June 01, 2013 04:59 PM

To: Lind, Denise COL USARMY (US)

Cc: David Coombs Hurley, Thomas MAJ USARMY Tooman,
Joshua CPT USARMY USARMY Morrow, JoDean (Joe) 111 CPT
USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY USARMY Ft McNair Mailbox MDW Court Reporters

USARMY USARMY

Subject: Government Filings, etc.

Ma'am,

Attached to this email are the following:

1. Completed Stipulation of Expected Testimony of SA Calder Robertson.

2. Based on the continuing obligation under Section and ongoing witness interviews, the United States submits
it's updated Section disclosures.

3. A third party filing for the Court. This filing was served in-person yesterday on the OSJ A, MDW for the Court.
A separate filing was also served on the Trial Counsel. The Government does not intend to file this third party

Page 464 of 2169

01782

filing on behalf of this organization.

4. Combined judicial notice list. The Court asked the parties to compile a combined judicial notice listing prior to
trial. The United States is finalizing the document to pass to the defense this afternoon. We have included defense

requested judicial notice as well.

5. As for the witness order for the first 25 witnesses, the United States intends to call SA Smith first then SA
Graham, which is a change from the previously filed order.

V/r
MAJ Fein

Page 465 of 2169

01783





From: Fein, Ashden MAJ USARMY MDW (US)

To: David Th MA ARMY TQQman, ,1 cm USARMY
- USARMY (us)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
?_c_xusmw us

Subject: Discovery Update

Date: Saturday, June 01,201312:18:00 AM

Defense,

We produced additional discovery under our ongoing discovery obligations. We have it available to deliver by hand
tomorrow, when you drop off the Robertson stipulation. There is classified and unclassified discovery.

BATES 00527646 00527777 is classified information including witness briefs, additional Katz information,
screenshots, and summaries for trial.

BATES 00527778 00527808 is unclassified information including pretrial recordings, witness bios, and a
different produced version of the OPSEC briefing recovered on digital evidence.

As we finalize them, we intend to provide copies of summaries we intend to use at trial prior to a witness's
testimony. This will be on a rolling basis.

V/r
MAJ Fein

Page 466 of 2169

01784





From: Hurley, Thomas MAJ USARMY (US)

To: in A MA ARMY MDW

Cc: Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY
Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT
USARMY USARMY USARMY Ft McNair Mailbox MDW Court Regorters

USARMY (US)

Subject: Robertson"s Stipulation

Date: Friday, May 31, 2013 1:43:32 PM

All

I have signed Robertson's stipulation, but I cannot scan it in. You guys going to be around the courthouse tomorrow
morning? I can just hand-deliver it then.

Thanks.

MAJ Hurley

Page 467 of 2169

01785

From: Tooman, Joshua CPT USARMY (US)
To: USARMY USAMDW (US)
Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW

"coombs arm courtmartialdefensecom"; Hurle Thomas MAJ USARMY US Trent Struttmann;?
us
Subject: Badge for Trent (UNCLASSIFIED)

Date: Friday, May 31, 2013 8:45:38 AM



Classification: UNCLASSIFIED

Caveats: NONE



(Gan you please add Trent to the list so he can park at the courthouse. Also, he?ll need a badge. He will be there for
)the start of trial on Monday.

Thanks!



Joshua J. Tooman
CPT, JA

Trial Defense Counsel
9990 Belvoir Drive



This communication may be privileged as attorney work product and/or attorney-client communication or may be
protected by another privilege recognized under the law. Do not distribute, forward, or release Without the prior
approval of the sender. In addition, this communication may contain individually identifiable information the
disclosure of Which, to any person or agency not entitled to receive it, is or may be prohibited by the Privacy Act, 5
U.S.C. ?5 52a. Improper disclosure of protected information could result in civil action or criminal prosecution.

Classification: UNCLASSIFIED

Caveats: NONE

Page 468 of 2169

01786

From: Tooman, Joshua CPT USARMY (US)
To: Morrow ,(QDean (Joe) QPT USARMY USAMDW Fein Ashden MA) USARMY MDW
rm rmrilfn.m"
Cc: Hurley, Thomas MAJ USARMY USARMY Overgaard, Angel CPT USARMY

Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine
?r_xcpT USARMY us us



Subject: Robertson Stip (UNCLASSIFIED)
Date: Thursday, May 30, 2013 6:10:03 PM
Attachments: RobertsonStig (FINAL 2 O).docx



Classification: UNCLASSIFIED
Caveats: NONE

All

FYI: I made an additional, non-substantive change to this stip. I altered
MAJ H's signature block to capture his rank, branch and duty position.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 1:24 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY am

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE
Josh,

Thanks. Looks good.

Page 469 of 2169

CPT Joe Morrow
Trial Counsel
US. Army Military District of Washington





From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 1:02 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Fein, Ashden MAJ USARMY
MDW 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von

Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Joe
See attached.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 12:46 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED

Page 470 of 2169

01787



01788

Caveats: NONE

Yes, make the change. Thank you.

CPT Joe Morrow
Trial Counsel
US. Army Military District of Washington





From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:45 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Fein, Ashden MAJ USARMY
MDW 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von

Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Joe

You are correct; I forgot the 12 JUL 07 portion. Would you like me to make
the change?

v/r
Josh

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir VA 22060

This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 12:43 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW

Page 471 of 2169

01789

'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

We have no objection to clarification, but I just re-checked the forensic

report and the file was named "12 Jul 07 CZ ENGAGEMENT ZONE GC Anyone.me".
I believe you left off the "12 Jul 07" below.

Bottom line - No objection to modifying the stip with the appropriate full
file name.

CPT Joe Morrow
Trial Counsel
US. Army Military District of Washington





From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:29 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a Video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.me." Assuming you do not have an issue
with this change and Howard County will allow SSG- to Visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,

Page 472 of 2169

Josh

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Page 473 of 2169

01790

01791

From: Fein Ashden MAJ USARMY MDW (US)
To: Tooman, (Joshua ,1 QPT USARMY
Cc: Hurley, Thomas MAJ USARMY USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY USARMY







(US)
Bcc:
Subject: RE: Stipulations (UNCLASSIFIED)
Date: Thursday, May 30, 2013 4:59:00 PM
Thank you!


From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 4:14 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All
Signed stips are attached.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, May 30, 2013 3:51 PM

To: Tooman, Joshua CPT USARMY
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT

Page 474 of 2169

01792

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stipulations (UNCLASSIFIED)

Gents,

Thanks. Once we receive them from MAJ Hurley, we will print and sign, and
then waive off the witness travel.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:29 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.wmv." Assuming you do not have an issue
with this change and Howard County will allow SSG- to visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,
Josh

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Page 475 of 2169

01793

From: Tooman, Joshua CPT USARMY (US)
To: Fain, MAJ USARMY MDW
Cc: Thomas MAJ USARMY US USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY USARMY






Subject: RE: Stipulations (UNCLASSIFIED)
Date: Thursday, May 30, 2013 4:14:13 PM
Attachments: Amiatu Stigpdf


Edwards Stippdf
Mairena Stigpdf
Marin Stigpdf
Young Stippdf



Classification: UNCLASSIFIED
Caveats: NONE

All

Signed stips are attached.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, May 30, 2013 3:51 PM

To: Tooman, Joshua CPT USARMY

Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stipulations (UNCLASSIFIED)

Gents,

Thanks. Once we receive them from MAJ Hurley, we will print and sign, and
then waive off the witness travel.

Page 476 of 2169

01794

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:29 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.wmv." Assuming you do not have an issue
with this change and Howard County will allow SSG- to visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,
Josh

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Page 477 of 2169

01795

From: Fein, Ashden MAJ USARMY MDW (US)
To: Tooman, (Joshua ,1 (PT USARMY
Cc: Thomas MAJ USARMY US USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY USARMY







(US)
Bcc:
Subject: RE: Stipulations (UNCLASSIFIED)
Date: Thursday, May 30, 2013 3:50:00 PM
Gents,

Thanks. Once we receive them from MAJ Hurley, we will print and sign, and
then waive off the witness travel.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:29 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.wmv." Assuming you do not have an issue
with this change and Howard County will allow SSG- to visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,
Josh

Classification: UNCLASSIFIED
Caveats: NONE

Page 478 of 2169

01796

From: Tooman, Joshua CPT USARMY (US)
To: rr PT ARMY AMDW Fein, Ashden MAJ USARMY MDW
rm rmrilfn.m"
Cc: Hurley, Thomas MAJ USARMY USARMY Overgaard, Angel CPT USARMY

Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine
CPT USARMY USARMY (US)

Subject: RE: Stipulations (UNCLASSIFIED)

Date: Thursday, May 30, 2013 1:28:46 PM



Classification: UNCLASSIFIED
Caveats: NONE

Great. SSG- will get it signed tomorrow morning.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



eged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 1:24 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
wsx? USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

Thanks. Looks good.

CPT Joe Morrow

Trial Counsel
US Army Military District of Washington

Page 479 of 2169





From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 1:02 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Fein, Ashden MAJ USARMY
MDW 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von

Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY am

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Joe
See attached.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060

This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 12:46 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY am

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Yes, make the change. Thank you.

Page 480 of 2169

01797





01798

CPT Joe Morrow
Trial Counsel
US. Army Military District of Washington



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:45 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Fein, Ashden MAJ USARMY
MDW 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von

Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Joe

You are correct; I forgot the 12 JUL 07 portion. Would you like me to make
the change?

v/r
Josh

Joshua J. Tooman
CPT, A

Trial Defense Counsel
9990 Belvoir Drive

This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 12:43 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

Page 481 of 2169

01799

USARMY
Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

We have no objection to clarification, but I just re-checked the forensic
report and the file was named "12 Jul 07 CZ ENGAGEMENT ZONE GC Anyone.wmv".
I believe you left off the "12 Jul 07" below.

Bottom line - No objection to modifying the stip with the appropriate full
file name.

CPT Joe Morrow
Trial Counsel
US. Army Military District of Washington





From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:29 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.wmv." Assuming you do not have an issue
with this change and Howard County will allow SSG- to visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,
Josh

Classification: UNCLASSIFIED
Caveats: NONE

Page 482 of 2169

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Page 483 of 2169

01800

01801

From: Tooman, Joshua CPT USARMY (US)
To: Morrow, a)QDean (Joe) QPT USARMY LJSAMDW Fein, Ashden MAJ USARMY MDW
rm rmrilfn.m"
Cc: Hurley, Thomas MAJ USARMY USARMY Overgaard, Angel CPT USARMY

Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine
?r_tcpt USARMY us ;?_c_tusmmv us



Subject: RE: Stipulations (UNCLASSIFIED)
Date: Thursday, May 30, 2013 1:01:41 PM
Attachments: RobertsonStip (FINAL 2.0).docx



Classification: UNCLASSIFIED
Caveats: NONE

Joe

See attached.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 12:46 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Yes, make the change. Thank you.
CPT Joe Morrow

Trial Counsel
US. Army Military District of Washington




Page 484 of 2169



01802



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:45 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Fein, Ashden MAJ USARMY
MDW 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von

Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY am

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Joe

You are correct; I forgot the 12 JUL 07 portion. Would you like me to make
the change?

v/r
Josh

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir VA 22060

This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 12:43 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED

Page 485 of 2169



01803

Caveats: NONE
Josh,

We have no objection to clarification, but I just re-checked the forensic
report and the file was named "12 Jul 07 CZ ENGAGEMENT ZONE GC Anyone.wmv".
I believe you left off the "12 Jul 07" below.

Bottom line - No objection to modifying the stip with the appropriate full
file name.

CPT Joe Morrow
Trial Counsel



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:29 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.wmv." Assuming you do not have an issue
with this change and Howard County will allow SSG- to visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,
Josh

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED

Page 486 of 2169

01804

Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Page 487 of 2169

01805

From: Tooman, Joshua CPT USARMY (US)
To: rr PT ARMY AMDW Fein Ashden MAJ USARMY MDW
rm rmrilfn.m"
Cc: Hurley, Thomas MAJ USARMY USARMY Overgaard, Angel CPT USARMY

Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine
CPT USARMY USARMY (US)

Subject: RE: Stipulations (UNCLASSIFIED)

Date: Thursday, May 30, 2013 12:45:10 PM



Classification: UNCLASSIFIED
Caveats: NONE

Joe

You are correct; I forgot the 12 JUL 07 portion. Would you like me to make
the change?

v/r
Josh

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Thursday, May 30, 2013 12:43 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY USARMY
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von
Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY am

Subject: RE: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

We have no objection to clarification, but I just re-checked the forensic

Page 488 of 2169

01806

report and the file was named "12 Jul 07 CZ ENGAGEMENT ZONE GC Anyone.wmv".
I believe you left off the "12 Jul 07" below.

Bottom line - No objection to modifying the stip with the appropriate full
file name.

CPT Joe Morrow
Trial Counsel
U.S. Arm Militar District of Washin ton





From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, May 30, 2013 12:29 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: Hurley, Thomas MAJ USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Stipulations (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.wmv." Assuming you do not have an issue
with this change and Howard County will allow SSG- to visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,
Josh

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED

Page 489 of 2169

01807

Caveats: NONE

Page 490 of 2169

01808

From: Tooman. Joshua CPT USARMY (US)
To: Fin Ah rm rmril
Cc: Thomas MAJ USARMY US USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY USARMY



(US)
Subject: Stipulations (UNCLASSIFIED)
Date: Thursday, May 30, 2013 12:28:52 PM



Classification: UNCLASSIFIED
Caveats: NONE

All

PFC Manning signed all the stips this morning with the exception of the
Calder Robertson stip. MAJ Hurley will sign them this afternoon and we will
forward them on.

As for Robertson, we request one more minor change and I apologize for not

catching it earlier. In paragraph 7c, towards the end, there is a sentence

that says, "One file contained no data and the other filed contained a Video

called 'Collateral Murder'." We would like to clarify that this file was

not actually named "Collateral Murder." Rather, it contained a file named

ENGAGEMENT ZONE 30 GC Anyone.me." Assuming you do not have an issue
with this change and Howard County will allow SSG- to Visit the

client, we should be able to have a corrected copy signed tomorrow.

Thanks,
Josh

Classification: UNCLASSIFIED
Caveats: NONE

Page 491 of 2169

01809





From: David Coombs

To: in A MA ARMY MDW

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
w; ?_
Subject: Additional Reciprocal Discovery

Date: Wednesday, May 29, 2013 6:14:05 PM

Attachments: 028711-028712.pdf


Ashden,

I have attached an additional three pages of reciprocal discovery. Please
let me know if you have any questions.

Best,
DaVid

DaVid E. Coombs, Esq.

Law Office of DaVid E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is

Page 492 of 2169

01810



From: Fein, Ashden MAJ USARMY MDW (US)

To: rm rmril fn . m"

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
w; ?_c_xusmw us

Subject: Re: Stipulations

Date: Wednesday, May 29, 2013 12:06:12 PM

Thank you.

Original Message

From: David Coombs [mailto:coombs armycourtmartialdefense.com]
Sent: Wednesday, May 29, 2013 04:00 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stipulations

Ashden,

We have reviewed all of the other stipulations and do not have an issues.
We will have these signed tomorrow and send them to you.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 8:03 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Page 493 of 2169

01811

Subject: Stipulations

David,

We have figured out how to combine tracked changes to figure out if other
changes have been made, so we will send the word versions going forward as
you requested. Below is a summary of the active stips we are tracking.
Marin. We accepted all changes we agreed to. We spoke with Marin again
this weekend and the following two changes remain: first, in paragraph 7,
we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to review all slides and we
incorporated his specific reference to information from the slides that he
remembers being taught on.

Clapper. Chain of custody information.

Edwards. Chain of custody information.

Young. Chain of custody information.

Mariena. Chain of custody information.

Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be
good to go.

This should be it for the first 25 witnesses. We will look one more time
tomorrow to see if there are any others.

v/r
Ashden

Page 494 of 2169

01812

From: David Coombs
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
J_ius ;?_c_iusmw us



Subject: RE: Stipulations
Date: Wednesday, May 29, 2013 12:00:27 PM
Ashden,

We have reviewed all of the other stipulations and do not have an issues.
We will have these signed tomorrow and send them to you.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 8:03 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stipulations
David,

We have figured out how to combine tracked changes to figure out if other
changes have been made, so we will send the word versions going forward as
you requested. Below is a summary of the active stips we are tracking.

Marin. We accepted all changes we agreed to. We spoke with Marin again
this weekend and the following two changes remain: first, in paragraph 7,
we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to review all slides and we

Page 495 of 2169

incorporated his specific reference to information from the slides that he
remembers being taught on.

Clapper. Chain of custody information.
Edwards. Chain of custody information.
Young. Chain of custody information.
Mariena. Chain of custody information.
Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be
good to go.

This should be it for the first 25 Witnesses. We will look one more time
tomorrow to see if there are any others.

V/r
Ashden

Page 496 of 2169

01813

01814

From: David Coombs
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
1?ius ;?_c_iusmw us



Subject: RE: Stipulations
Date: Wednesday, May 29, 2013 10:49:36 AM
Ashden,

No issues with the changes. We should be able to get back to you by noon on
the other stipulations. Assuming that they are good, we will have them
signed tomorrow morning by PFC Manning.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, May 29, 2013 10:25 AM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stipulations

David,

Attached is Marin's stip. We accepted all your changes; however cleaned up
the language at the end of paragraph 8 and added "number" or "numbers" after


Old: "1 also cannot say for certain that these are the slides due to the

fact that not all of the slides were covered in a class due to time
constraints or a class being shortened."

Page 497 of 2169

01815

New: also cannot say for certain that these are the slides because not
all of the slides were used in all the classes due to time constraints or a
class being shortened."

If you are good with these, then the PDF is attached ready to go with your
client.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Wednesday, May 29, 2013 8:05 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stipulations
Ashden,

We will get back to you later today on the other stipulations. I have

attached the changes to SSG Marin's stipulation that the Defense would agree
to. These changes are based upon our communications with him over the
weekend and early this morning.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 9:40 PM

To: 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

Page 498 of 2169

01816

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Re: Stipulations
David. We spoke to him yesterday- Monday.

Vr
Ashden

Original Message

From: David Coombs [m il rm i m]

Sent: Wednesday, May 29, 2013 12:11 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stipulations
Ashden,
What day did you speak with SSG Marin?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 8:03 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stipulations

David,

Page 499 of 2169

01817

We have figured out how to combine tracked changes to figure out if other
changes have been made, so we will send the word versions going forward as
you requested. Below is a summary of the active stips we are tracking.
Marin. We accepted all changes we agreed to. We spoke with Marin again
this weekend and the following two changes remain: first, in paragraph 7,
we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to reView all slides and we
incorporated his specific reference to information from the slides that he
remembers being taught on.

Clapper. Chain of custody information.

Edwards. Chain of custody information.

Young. Chain of custody information.

Mariena. Chain of custody information.

Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be
good to go.

This should be it for the first 25 witnesses. We will look one more time
tomorrow to see if there are any others.

V/r
Ashden

Page 500 of 2169

01818

From: Fein, Ashden MAJ USARMY MDW (US)
To: vi
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
J_xus ;?_c_xusmw us











Bcc:
Mitroka Katherine
CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW (US)
Subject: RE: Stipulations
Date: Wednesday, May 29. 2013 9:48:00 AM

Attachments: 130529-Stipulation of Expected Testimony (MarinA).pdf



David,

Attached is Marin's stip. We accepted all your changes; however cleaned up the language at the end of paragraph 8
and added "number" or "numbers" after

Old: "1 also cannot say for certain that these are the slides due to the fact that not all of the slides were covered in a
class due to time constraints or a class being shortened."

New: also cannot say for certain that these are the slides because not all of the slides were used in all the classes
due to time constraints or a class being shortened."

If you are good with these, then the PDF is attached ready to go with your client.

v/r
Ashden



From: David Coombs [m il rm i m]

Sent: Wednesday, May 29, 2013 8:05 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

USARMY Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY
Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka,

Katherine CPT USARMY USARMY (US)

Subject: RE: Stipulations
Ashden,

We will get back to you later today on the other stipulations. I have

attached the changes to SSG Marin's stipulation that the Defense would agree
to. These changes are based upon our communications with him over the
weekend and early this morning.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com

Page 501 of 2169

01819



>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 9:40 PM

To: 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Re: Stipulations
David. We spoke to him yesterday- Monday.

Vr
Ashden

Original Message

From: David Coombs [mailtozcoombs armycourtmartialdefense.com]

Sent: Wednesday, May 29, 2013 12:11 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stipulations
Ashden,
What day did you speak with SSG Marin?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the

Page 502 of 2169

01820

person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 8:03 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stipulations

David,

We have figured out how to combine tracked changes to figure out if other
changes have been made, so we will send the word versions going forward as
you requested. Below is a summary of the active stips we are tracking.
Marin. We accepted all changes we agreed to. We spoke with Marin again
this weekend and the following two changes remain: first, in paragraph 7,
we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to review all slides and we
incorporated his specific reference to information from the slides that he
remembers being taught on.

Clapper. Chain of custody information.

Edwards. Chain of custody information.

Young. Chain of custody information.

Mariena. Chain of custody information.

Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be
good to go.

This should be it for the first 25 witnesses. We will look one more time
tomorrow to see if there are any others.

v/r
Ashden

Page 503 of 2169

01821

From: Tooman, Joshua CPT USARMY (US)

To: USARMY USAMDW Fain MAJ USARMY MDW Morrow ,googan (dog)
PT ARMY AMDW

Cc: David Coombs; Hurley Thomas MAJ USARMY USARMY (US)

Subject: Secret Printer (UNCLASSIFIED)

Date: Wednesday, May 29, 2013 9:39:49 AM



Classification: UNCLASSIFIED
Caveats: NONE



(W are in need of more ink for our Secret printer. It is a Dell Model
#3130cn. How should we go about obtaining this need?



Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: USARMY (US)
Sent: Wednesday, May 29, 2013 9:37 AM

To: Tooman, Joshua CPT USARMY (US)
Subject: SIPR Printer (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Good morning,

The printer is a Dell 3130cn.



ssa-

Classification: UNCLASSIFIED
Caveats: NONE

Page 504 of 2169

01822

Classification: UNCLASSIFIED
Caveats: NONE

Page 505 of 2169

01823

From: David Coombs
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
w; ?_c_iusmw us
Subject: RE: Stipulations
Date: Wednesday, May 29, 2013 8:05:53 AM

Attachments: 130528-Stipulation of Expected Testimony (MarinA).docx



Ashden,

We will get back to you later today on the other stipulations. I have

attached the changes to SSG Marin's stipulation that the Defense would agree
to. These changes are based upon our communications with him over the
weekend and early this morning.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 9:40 PM

To: 'coombs armycourtmartialdefense.com'

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Re: Stipulations
David. We spoke to him yesterday- Monday.

Vr
Ashden

Original Message
From: David Coombs [m il rm ri m]

Page 506 of 2169

01824

Sent: Wednesday, May 29, 2013 12:11 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: RE: Stipulations
Ashden,
What day did you speak with SSG Marin?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 8:03 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stipulations
David,

We have figured out how to combine tracked changes to figure out if other
changes have been made, so we will send the word versions going forward as
you requested. Below is a summary of the active stips we are tracking.

Marin. We accepted all changes we agreed to. We spoke with Marin again
this weekend and the following two changes remain: first, in paragraph 7,
we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to review all slides and we
incorporated his specific reference to information from the slides that he
remembers being taught on.

Page 507 of 2169

01825

Clapper. Chain of custody information.
Edwards. Chain of custody information.
Young. Chain of custody information.
Mariena. Chain of custody information.
Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be
good to go.

This should be it for the first 25 Witnesses. We will look one more time
tomorrow to see if there are any others.

V/r
Ashden

Page 508 of 2169

01826

From: Fein Ashden MAJ USARMY MDW (US)
To: rm rmril fn . m"
Cc: Hurley Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
1?)us us



Bcc:
CPT USARMY (US)
Subject: Re: Stipulations
Date: Tuesday, May 28, 2013 9:40:27 PM



David. We spoke to him yesterday- Monday.

Vr
Ashden

Original Message

From: David Coombs [m il rm i m]

Sent: Wednesday, May 29, 2013 12:11 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Mitroka, Katherine CPT USARMY USARMY (US)

Subject: RE: Stipulations

Ashden,
What day did you speak with SSG Marin?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 8:03 PM

Page 509 of 2169

01827

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stipulations

David,

We have figured out how to combine tracked changes to figure out if other
changes have been made, so we will send the word versions going forward as
you requested. Below is a summary of the active stips we are tracking.
Marin. We accepted all changes we agreed to. We spoke with Marin again
this weekend and the following two changes remain: first, in paragraph 7,
we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to review all slides and we
incorporated his specific reference to information from the slides that he
remembers being taught on.

Clapper. Chain of custody information.

Edwards. Chain of custody information.

Young. Chain of custody information.

Mariena. Chain of custody information.

Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be
good to go.

This should be it for the first 25 witnesses. We will look one more time
tomorrow to see if there are any others.

v/r
Ashden

Page 510 of2169

01828

From: David Coombs
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
1?ius ;?_c_iusmw us



Subject: RE: Stipulations
Date: Tuesday, May 28, 2013 8:11:41 PM
Ashden,

What day did you speak with SSG Marin?

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 8:03 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
USARMY Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine

CPT USARMY USARMY (US)

Subject: Stipulations
David,

We have figured out how to combine tracked changes to figure out if other
changes have been made, so we will send the word versions going forward as
you requested. Below is a summary of the active stips we are tracking.

Marin. We accepted all changes we agreed to. We spoke with Marin again
this weekend and the following two changes remain: first, in paragraph 7,
we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to review all slides and we
incorporated his specific reference to information from the slides that he

Page 511 of2169

01829

remembers being taught on.

Clapper. Chain of custody information.
Edwards. Chain of custody information.
Young. Chain of custody information.
Mariena. Chain of custody information.
Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be
good to go.

This should be it for the first 25 Witnesses. We will look one more time
tomorrow to see if there are any others.

V/r
Ashden

Page 512 of2169

01830

From: Fein, Ashden MAJ USARMY MDW (US)
To: vi
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka Katherine CPT USARMY
J_xus ;?_c_xusmw us





Subject: Stipulations
Date: Tuesday, May 28, 2013 8:03:00 PM

Attachments: 130528-Stipulation of Expected Testimony (AmiatuM).docx
130528-Stipulation of Expected Testimony (ClapperC).docx
130528-Stipulation of Expected Testimony (EdwardsA).docx
130528-Stipulation of Expected Testimony (MairenaT).docx
130528-Stipulation of Expected Testimony (MarinA).docx
130528-Stipulation of Expected Testimony (YoungG).docx



David,

We have figured out how to combine tracked changes to figure out if other changes have been made, so we will send
the word versions going forward as you requested. Below is a summary of the active stips we are tracking.

Marin. We accepted all changes we agreed to. We spoke with Marin again this weekend and the following two
changes remain: first, in paragraph 7, we rewrote the sentence you deleted relating to second, in paragraph
8, SSG Marin has since had the opportunity to review all slides and we incorporated his specific reference to
information from the slides that he remembers being taught on.

Clapper. Chain of custody information.

Edwards. Chain of custody information.

Young. Chain of custody information.

Mariena. Chain of custody information.

Amiatu. JAMMS records.

Robertson. Joe sent this on Monday and Josh confirmed that it should be good to go.

This should be it for the first 25 witnesses. We will look one more time tomorrow to see if there are any others.

v/r
Ashden

Page 513 of2169

01831



From: David Coombs

To: in A MA ARMY MDW Tooman, Joshua ,1 QPT LJSARMY MerQw, (dog) QPT
LJSARMY LJSAMDW Anggl QPT LJSARMY (L13)

Cc: Hurley, Thomas MAJ USARMY USARMY (US)

Subject: RE: Mr. Adkins

Date: Tuesday, May 28, 2013 7:17:21 PM

Thank you.

Best

David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>linformation and is intended for the person(s) or company named. If you are not the intended recipient, please notify
the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be unlawful and
is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, May 28, 2013 6:14 PM

To: David Coombs; Tooman, Joshua CPT USARMY Morrow, oDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY USARMY (US)
Subject: RE: Mr. Adkins

David,

SFC (R) Adkins can be reached at? or at?
v/r

Ashden



From: David Coombs [m il rm i m]

Sent: Sunday, May 26, 2013 9:21 AM
To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY USARMY (US)
Subject: Mr. Adkins

Ashden,

Page 514 of2169

01832

Please provide me with the best contact information for Mr. Adkins. Thank you.

Best,

David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508) 689-9282
coombs armycourtmartialdefense.com



Page 515 of2169

01833





From: Fein, Ashden MAJ USARMY MDW (US)
To: "David gagmbs"; PT ARMY Morrow, a)gzDean (Joe) QPT LJSARMY LJSAMDW
vr An IM PT ARMY
Cc: Hurley Thomas MAJ USARMY USARMY (US)
Bcc:
USARMY
Mitroka, Katherine CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Whyte, Hunter CPT USARMY (US)
Subject: RE: Mr. Adkins
Date: Tuesday, May 28, 2013 6:14:00 PM
David,
Adkins be reached at? or at?
v/r
Ashden


From: David Coombs [mailto:coombs armycourtmartialdefense.com]
Sent: Sunday, May 26, 2013 9:21 AM
To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY (US)
Cc: Hurley, Thomas MAJ USARMY USARMY (US)
Subject: Mr. Adkins

Ashden,

Please provide me with the best contact information for Mr. Adkins. Thank you.

Best,

David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508) 689-9282
coombs armycourtmartialdefense.com



Page 516 of2169

01834







From: Tooman Joshua CPT USARMY (US)

To: Morrow. JoDean (Joe) CPT USARMY USAMDW (US)

Cc: David E. Coombs; Hurlev. Thomas MAJ USARMY (US): Fein. Ashden MAJ USARMY MDW (US):
- USARMY (US)

Subject: RE: Final Robertson Stip (UNCLASSIFIED)

Date: Monday, May 27, 2013 11:39:56 AM

Joe

The Robertson stip looks good to me. Would you like us to print this version for BM's signature?



Josh



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Monday, May 27, 2013 11:30 AM

To: Tooman, Joshua CPT USARMY (US)

Cc: David E. Coombs; Hurley, Thomas MAJ USARMY Fein, Ashden MAJ USARMY MDW
USARMY (US)

Subject: RE: Final Robertson Stip (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Thanks.

CPT Joe Morrow

Trial Counsel
US. Army Military District of Washington





From: Tooman, Joshua CPT USARMY (US)

Sent: Monday, May 27, 2013 11:26 AM

To: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Cc: David E. Coombs; Hurley, Thomas MAJ USARMY Fein, Ashden MAJ
USARMY MDW USARMY (US)

Subject: RE: Final Robertson Stip (UNCLASSIFIED)

Got it. Thanks, Joe. I'll takealook.

Ideally, we'll be able to take a bunch of these stips to BM at one time. I
hope we can take a batch to him mid-week.

Page 517 of2169

01835

Happy Memorial Day to you, as well.

Josh



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Monday, May 27, 2013 11:18 AM

To: Tooman, Joshua CPT USARMY (US)

Cc: David E. Coombs; Hurley, Thomas MAJ USARMY Fein, Ashden MAJ
USARMY MDW USARMY (US)

Subject: Final Robertson Stip (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

See attached. Every comment you made has been addressed. With item 6, I
believe any confusion is addressed by paragraph 9, which describes what
Robertson is talking about when he says he collected two specific items of
evidence and annotated that collection on DN 073-10. I added one sentence
in paragraph 9 to make this more clear - collected this evidence at the
CID office on Camp Liberty."

Item 1 in your email is addressed in paragraph 4.

Item 2 in your email is addressed in paragraph 7d.

Item 3 in your email is addressed in paragraph 7d.

Item 4 in your email is addressed in paragraph 7e. Per our phone discussion
yesterday and our agreement, I left A's name as Robertson remembers that.
All the rest of the text has been added verbatim from your email to make it

clear that the contact information was not of a personal nature.

Item 5 in your email is addressed in paragraph 7f.

Finally, do you have any idea when you'll be able to run this stipulation by
PFC

Happy Memorial Day.

Page 518 of2169

01836

CPT Joe Morrow
Trial Counsel

US. Army Military District of Washington

Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Page 519 of2169

01837

From: Tooman, Joshua CPT USARMY (US)

To: rr PT ARMY AMDW

Cc: David E. Coombs; Hurley, Thomas MAJ USARMY Fein, Ashden MAJ USARMY MDW
- USARMY (US)

Subject: RE: Final Robertson Stip (UNCLASSIFIED)

Date: Monday, May 27, 2013 11:25:35 AM



Got it. Thanks, Joe. I'll takealook.

Ideally, we'll be able to take a bunch of these stips to BM at one time. I hope we can take a batch to him mid-week.

Happy Memorial Day to you, as well.

Josh



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Monday, May 27, 2013 11:18 AM

To: Tooman, Joshua CPT USARMY (US)

Cc: David E. Coombs; Hurley, Thomas MAJ USARMY Fein, Ashden MAJ USARMY MDW
USARMY (US)

Subject: Final Robertson Stip (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

See attached. Every comment you made has been addressed. With item 6, I believe any confusion is addressed by
paragraph 9, which describes what Robertson is talking about when he says he collected two specific items of
evidence and annotated that collection on DN 073-10. I added one sentence in paragraph 9 to make this more clear
collected this evidence at the CID office on Camp Liberty.?

Item 1 in your email is addressed in paragraph 4.

Item 2 in your email is addressed in paragraph 7d.

Item 3 in your email is addressed in paragraph 7d.

Item 4 in your email is addressed in paragraph 7e. Per our phone discussion yesterday and our agreement, I left

A?s name as Robertson remembers that. All the rest of the text has been added verbatim from your email to make
it clear that the contact information was not of a personal nature.

Page 520 of 2169

01838

Item 5 in your email is addressed in paragraph 7f.

Finally, do you have any idea when you?ll be able to run this stipulation by PFC

Happy Memorial Day.

CPT Joe Morrow

Trial Counsel

US. Army Military District of Washington

Classification: UNCLASSIFIED
Caveats: NONE

Page 521 of 2169

01839



From: David Coombs

To: Fein, Ashden MAJ LJSARMY MDW Hurley, Thomas MAJ LJSARMY ngman, (Joshua ,1 QPT LJSARMY
?51;

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Word Versions and VTC/Telephonic Testimony

Date: Sunday, May 26, 2013 8:16:42 PM

Ashden,

Your comments do not make sense to me regarding PDF versus Word versions.
The stipulations are collaborative documents and you do not get to control

the editing of the documents. Using track changes, the way the rest of the
world does, is a much quicker way of facilitating the process than by having

us tell you what changes we want, having you make those changes, and then us
reviewing the changes, and possibly getting back to you with additional
concerns. Ultimately, the Defense is the side with the final say on any
stipulation, since it is our client who is waiving his Sixth Amendment

rights. If you don't like the stipulation that we can agree to, then it is

your prerogative to bring the witness.

Also, you must have either sent your message with a delayed delivery option,
or you failed to see that I have already sent an edited version with track
changes for SSG Marin's stipulation in Word. Regardless, we will be sending
back track changes documents in Word for any stipulation for this point
forward. Additionally, your plan of doing stipulations witness by witness
seems to be yet another example of a lack of due diligence. You have known
for over two months the names of the witnesses that we would likely
stipulate to. How we are at a week before trial with so few stipulations
completed is beyond me, but it has nothing to do with the Defense. At the
current rate of a witness or two per day, we will be wrapping up the
stipulations towards the end of trial.

To clarify once again, the Defense has never changed its positions on
stipulations of expected testimony. We simply did not agree to entering
into stipulations of admissibility for documents and evidence. The fact
that you did not understand this position or did not want to accept this
position is not the Defense's fault.

Finally, with regards to the telephonic testimony, our position is, has, and
continues to be that if you have an OCONUS witness that you do not want to
bring in person and instead want them to testify either by VTC or
telephonically, we will likely agree to that request. All you need to do is
give us a list of those witnesses and we will let you know if we would

object to remote testimony for any specifically listed witness.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Page 522 of 2169

01840

Fax: (508) 689-9282
coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Sunday, May 26, 2013 7:47 PM

To: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY USARMY (US)

Cc: Morrow, oDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: Word Versions and VTC/Telephonic Testimony

David,

The reason we are not sending them in word version is so that we can track
exactly what changes the defense would like to make and we can continue
pushing through the stipulations. As you know, both parties have agreed to
80+ stipulations, and we have to prepare them as we prepare for trial. It

is more efficient if the defense sends us the comments, like Josh did

earlier for Robertson, so we can review just the proposed changes, have a
discussion with the defense if needed, and then make the changes and move on
to the next.

For the past few months, the defense team members have unfortunately changed
their positions on stipulations and what is acceptable or not. To get this

done in time and efficiently, the trial counsel must keep control of the
documents so we know exactly what has changed or not- tracked changes does
not necessarily do that. For example, we now have to spend time going

through, word-for-word, the Marin Stip you sent back to validate whether

this is the information the trial counsel agreed upon and the witness would
testify to based on our multiple conversations, and then review your

proposed edits. If the parties truly want 80+ stipulations, then this time

is better spent working on the next stipulations and coordinating travel.

In the spirit of ongoing cooperation and collaboration, attached are the two
most recent stips in word version. With only one week until trial, we will
continue to send the PDF versions so we (prosecution and defense) can knock
these out VERY quickly.

Finally, as for telephonic testimony, we will provide a list in our next

update to the witness list order. Although the Court did get clarification
from your client himself during the last 39(a), defense counsel prior to

that consistently stated the defense would agree to VTC/telephonic testimony
for "any" or "all" OCONUS witnesses. Are there any specific witnesses that
you will object to, so that the parties know going forward for planning
purposes and don't have to spend time figuring this out?

Page 523 of 2169

01841

V/r
Ashden

Page 524 of 2169

01842

From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ LJSARMY TQQman, (Joshua ,1 QPT LJSARMY


Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY



USARMY (US)
Bcc:
Subject: Word Versions and VTC/Telephonic Testimony
Date: Sunday, May 26, 2013 7:47:00 PM

Attachments: 130524-Stig of Expected Testimony (MarinA) (FOR
130524-Stipulation of Expected Testimony (RobertsonC) (FOR



David,

The reason we are not sending them in word version is so that we can track exactly what changes the defense would
like to make and we can continue pushing through the stipulations. As you know, both parties have agreed to 80+
stipulations, and we have to prepare them as we prepare for trial. It is more efficient if the defense sends us the
comments, like Josh did earlier for Robertson, so we can review just the proposed changes, have a discussion with
the defense if needed, and then make the changes and move on to the next.

For the past few months, the defense team members have unfortunately changed their positions on stipulations and
what is acceptable or not. To get this done in time and efficiently, the trial counsel must keep control of the
documents so we know exactly what has changed or not- tracked changes does not necessarily do that. For
example, we now have to spend time going through, word-for-word, the Marin Stip you sent back to validate
whether this is the information the trial counsel agreed upon and the witness would testify to based on our multiple
conversations, and then review your proposed edits. If the parties truly want 80+ stipulations, then this time is
better spent working on the next stipulations and coordinating travel.

In the spirit of ongoing cooperation and collaboration, attached are the two most recent stips in word version. With
only one week until trial, we will continue to send the PDF versions so we (prosecution and defense) can knock
these out VERY quickly.

Finally, as for telephonic testimony, we will provide a list in our next update to the witness list order. Although the
Court did get clarification from your client himself during the last 39(a), defense counsel prior to that consistently
stated the defense would agree to VTC/telephonic testimony for "any" or "all" OCONUS witnesses. Are there any
specific witnesses that you will object to, so that the parties know going forward for planning purposes and don't
have to spend time figuring this out?

v/r
Ashden

Page 525 of 2169

01843

From: David Coombs
To: Wh Hn PT ARMY ;Hr FMA ARMY mn PT ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: Stipulation of Expected Testimony
Date: Sunday, May 26, 2013 2:13:48 PM

Attachments: 130524-Stip of Expected Testimony (MarinA).doc



Hunter,

Here are the changes that we would require in order to stipulate to SSG
Marin's testimony. Let me know if you have any questions.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Whyte, Hunter CPT USARMY (US)
Sent: Friday, May 24, 2013 6:36 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY von Elten, Alexander
(Alec) CPT USARMY Mitroka, Katherine CPT USARMY
- USARMY Fein, Ashden MAJ USARMY MDW

'coombs armycourtmartialdefense.com'

Subject: Stipulation of Expected Testimony

Gents,

Attached is a proposed stipulation of expected testimony for SSG Alejandro
Marin. As you know, SSG Marin is currently deployed and he is also one of
our first 25 witnesses. For that reason, can you please let us know your
thoughts on the attached stipulation, so everyone (especially his command in
theater) is on notice when we need to coordinate his travel for the
court-martial? Thank you!

Have a good weekend!

Page 526 of 2169

01844

V/r
Hunter

Page 527 of 2169

01845



From: David Coombs

To: ,lQDgan mg) QPT LJSARMY LJSAMDW Tooman, ,1ng Hurley, Thomas
MAJ LJSARMY

Co: Fein, Ashden MAJ USARMY MDW USARMY (US)

Subject: RE: Robertson stipulation (UNCLASSIFIED)

Date: Sunday, May 26, 2013 11:16:50 AM

Joe,

With regards to OCONUS witnesses, our position has always been that if you have a list of OCONUS witnesses that
you would want to testify telephonically, we would likely not object. However, we needed to have a list of those
witnesses to ensure that we did not want a particular one in person. This was covered by the Court during our last
39(a).

Best,

David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508) 689-9282
coombs armycourtmartialdefense.com



>l<>l<>linformation and is intended for the person(s) or company named. If you are not the intended recipient, please notify
the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be unlawful and
is

From: Morrow, JoDean (Joe) CPT USARMY USAMDW (US)

Sent: Sunday, May 26, 2013 10:32 AM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ
USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)

Subject: Re: Robertson stipulation (UNCLASSIFIED)

Page 528 of 2169

01846

David,

I will talk to Josh later today and finalize. However, Robertson is an OCONUS witness and my understanding was
that you all were waiving the personal appearance of OCONUS witnesses anyway. As such, I didn't think this
would be a big deal. Sorry for my confusion.

CPT Morrow

From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Sunday, May 26, 2013 02:27 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Tooman, Joshua CPT USARMY Hurley,
Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)

Subject: RE: Robertson stipulation (UNCLASSIFIED)

Joe,

Until we have an agreement, I would not turn off any travel arrangements. I understand that you need to review the
changes we recommended and then put them into the stipulation. After you do so, we will need to review the
stipulation again to ensure that it captures our intent. This process underscores why the Government should just
send the stipulations to us in Word. The stipulations are a collaborative document and should be viewed as such.
We can make the our changes by using Word?s track changes function. Once we do, then you will either accept the
changes or you won?t.

Best,

David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508) 689-9282
coombs armycourtmartialdefense.com



>l<>l<>l
Page 529 of 2169

01847

information and is intended for the person(s) or company named. If you are not the intended recipient, please notify
the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be unlawful and
is

From: Morrow, JoDean (Joe) CPT USARMY USAMDW (US)

Sent: Sunday, May 26, 2013 10:10 AM
To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW
USARMY (US)

Subject: Re: Robertson stipulation (UNCLASSIFIED)

Josh,

I will take a closer look at your requests tonight, but I do not see any major issues with what you have proposed. If
you agree, I would like to turn off travel for Robertson. Thoughts?
CPT Morrow

From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, May 26, 2013 12:17 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW 'David Coombs'
USARMY (US)

Subject: RE: Robertson stipulation (UNCLASSIFIED)

Joe

I was able to speak with SA Robertson this morning. Overall, I think we are very close. Just a few thoughts:

1. Please add a description of a preliminary forensic exam. Something like, conducted preliminary forensic

examinations on a number of pieces of evidence seized in this case. A preliminary examination is a high level
review taking no more than a couple hours, whereas a full forensic examination can take from one day to a full
week."

2. Paragraph 7d. Please add something to the effect of, did not note the machine's username."

3. Paragraph 7d. Please change the following sentence to: also reviewed the "user" files associated with account
resembling PFC Manning?s name and located several files containing text that was specifically referenced in the
chat logs received by US. Army CID during the initial phases of the investigation, though I did not specifically
note which text was referenced in chat logs."

Page 530 of 2169

01848

4. Paragraph 7e. Please change this so it is consistent with the AIR, reviewed a file that appeared to contain
contact information for a member of the WikiLeaks Team. This contact information appeared to have been
produced and released by the WikiLeaks team and did not appear to be of a personal nature."

5. Paragraph 7f. Please change to, also found an archive file that contained approximately 11,000 sensitive and
classified documents, downloaded in Hyper Text Markup Language (HTML) format, though I did not note the
exact number."

6. Paragraph 7, generally. Most subparagraphs indicate, know this because I This could be
confusing because he specificlally states in paragraph four that the evidence was collected at FOB Hammer and
delivered to him at Camp Liberty. Not sure how to clarify this. Your thoughts?

Any issues, give me a call a?

Thanks,

Josh



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Friday, May 24, 2013 11:23 AM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY (US)
Cc: Fein, Ashden MAJ USARMY MDW (US)

Subject: Robertson stipulation (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

Attached is the Calder Robertson stipulation. Let me know what you think as soon as you can. Are you still having
trouble reaching him? He has not been readily accessible on our end either, but we let him know (again) that you
wanted to speak with him. If I can facilitate further to wrap this up, let me know soon. Best time to reach out to
Germany would be about now.

CPT Joe Morrow
Trial Counsel

US. Army Military District of Washington

Page 531 of 2169

01849

Classification: UNCLASSIFIED
Caveats: NONE

Page 532 of 2169

01850



From: David Coombs

To: Morrow, ,!QDgan mg) QPT USARMY LJSAMDW Tooman, ,lgghua ,1ng Hurley, Thomas
MAJ USARMY

Co: Fein, Ashden MAJ USARMY MDW USARMY (US)

Subject: RE: Robertson stipulation (UNCLASSIFIED)

Date: Sunday, May 26, 2013 10:27:27 AM

Joe,

Until we have an agreement, I would not turn off any travel arrangements. I understand that you need to review the
changes we recommended and then put them into the stipulation. After you do so, we will need to review the
stipulation again to ensure that it captures our intent. This process underscores why the Government should just
send the stipulations to us in Word. The stipulations are a collaborative document and should be viewed as such.
We can make the our changes by using Word?s track changes function. Once we do, then you will either accept the
changes or you won?t.

Best,

David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508) 689-9282
coombs armycourtmartialdefense.com



>l<>l<>linformation and is intended for the person(s) or company named. If you are not the intended recipient, please notify
the sender and delete all copies. Unauthorized disclosure, copying or use of this information may be unlawful and
is

From: Morrow, JoDean (Joe) CPT USARMY USAMDW (US)

Sent: Sunday, May 26, 2013 10:10 AM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW
USARMY (US)

Page 533 of 2169

01851

Subject: Re: Robertson stipulation (UNCLASSIFIED)

Josh,

I will take a closer look at your requests tonight, but I do not see any major issues with what you have proposed. If
you agree, I would like to turn off travel for Robertson. Thoughts?
CPT Morrow

From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, May 26, 2013 12:17 PM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW 'David Coombs'
USARMY (US)

Subject: RE: Robertson stipulation (UNCLASSIFIED)

Joe

I was able to speak with SA Robertson this morning. Overall, I think we are very close. Just a few thoughts:

1. Please add a description of a preliminary forensic exam. Something like, conducted preliminary forensic

examinations on a number of pieces of evidence seized in this case. A preliminary examination is a high level
review taking no more than a couple hours, whereas a full forensic examination can take from one day to a full
week."

2. Paragraph 7d. Please add something to the effect of, did not note the machine's username."

3. Paragraph 7d. Please change the following sentence to: also reviewed the "user" files associated with account
resembling PFC Manning?s name and located several files containing text that was specifically referenced in the
chat logs received by US. Army CID during the initial phases of the investigation, though I did not specifically
note which text was referenced in chat logs."

4. Paragraph 7e. Please change this so it is consistent with the AIR, reviewed a file that appeared to contain
contact information for a member of the WikiLeaks Team. This contact information appeared to have been
produced and released by the WikiLeaks team and did not appear to be of a personal nature."

5. Paragraph 7f. Please change to, also found an archive file that contained approximately 11,000 sensitive and
classified documents, downloaded in Hyper Text Markup Language (HTML) format, though I did not note the
exact number."

Page 534 of 2169

01852

6. Paragraph 7, generally. Most subparagraphs indicate, know this because I This could be
confusing because he specificlally states in paragraph four that the evidence was collected at FOB Hammer and
delivered to him at Camp Liberty. Not sure how to clarify this. Your thoughts?

Any issues, give me a call a?

Thanks,

Josh



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Friday, May 24, 2013 11:23 AM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY (US)
Cc: Fein, Ashden MAJ USARMY MDW (US)

Subject: Robertson stipulation (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

Attached is the Calder Robertson stipulation. Let me know what you think as soon as you can. Are you still having
trouble reaching him? He has not been readily accessible on our end either, but we let him know (again) that you
wanted to speak with him. If I can facilitate further to wrap this up, let me know soon. Best time to reach out to
Germany would be about now.

CPT Joe Morrow
Trial Counsel

US. Army Military District of Washington

Classification: UNCLASSIFIED
Caveats: NONE

Page 535 of 2169

01853



From: David Coombs

To: Fain, LJSARMY MDW ms); TQQman, QPT LJSARMY ms); Morrow, ,lngan (,lgg) QPT
LJSARMY LJSAMDW ms); Anggl QPT LJSARMY (us)

Cc: Hurley, Thomas MAJ USARMY USARMY (US)

Subject: Mr. Adkins

Date: Sunday, May 26, 2013 9:21 :15 AM

Ashden,

Please provide me with the best contact information for Mr. Adkins. Thank you.

Best,

David

David E. Coombs, Esq.

Law Office of David E. Coombs
11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156
Local: (508) 689-4616

Fax: (508) 689-9282
coombs armycourtmartialdefense.com



Page 536 of 2169

01854



From: FeinI Ashden MAJ USARMY MDW (US)

To: TQQman, Joshua ,1 QPT rr PT ARMY AMDW Angel
QPT LJSARMY (LJS)

Cc: Hurley, Thomas MAJ USARMY USARMY
1&1

Subject: Re: Struttmann Subpoena (UNCLASSIFIED)

Date: Sunday, May 26, 2013 9:06:50 AM

Thank you.

From: Tooman, Joshua CPT USARMY (US)

Sent: Sunday, May 26, 2013 10:47 AM

To: Fein, Ashden MAJ USARMY MDW Morrow, oDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ
USARMY USARMY (US)

Subject: RE: Struttmann Subpoena (UNCLASSIFIED)

Sir

Cyber Agents did not receive the documents. Also, Trent noticed a couple errors.

1. Theiraddress

2. His last name is spelled Struttmann. Two on the end.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, May 24, 2013 5:02 PM

To: Tooman, Joshua CPT USARMY Morrow, oDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY
USARMY (US)

Subject: RE: Struttmann Subpoena (UNCLASSIFIED)

Josh,
We sent Mr. Struttman his subpoena and travel worksheet via certified mail
on 29 Apr 13. The tracking number is 7010 1060 001 1274 4460. We have not

received the return receipt. A copy is attached to this email. Please have
him let us know whether CyberAgents did not receive the documents.

Page 537 of 2169

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, May 22, 2013 3:08 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY
USARMY (US)

Subject: Struttmann Subpoena (UNCLASSIFIED)

Classification: UNCLASSIFIED

Caveats: NONE

Sir

Could you all send a subpoena to Trent? Doing so will ensure a subsequent
subpoena for other cases doesn't slip in and complicate his presence.

Thanks,

Josh

Joshua J. Tooman
CPT, JA

Trial Defense Counsel

9990 Belvoir Drive

Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.

Classification: UNCLASSIFIED

Caveats: NONE

Page 538 of 2169

01855

01856

Page 539 of 2169

01857



From: Tooman, Joshua CPT USARMY (US)
To: PT ARMY AMDW r Th FMA ARMY

Cc: Fein, Ashden MAJ USARMY MDW "David Coombs"; USARMY (US)
Subject: RE: Robertson stipulation (UNCLASSIFIED)

Date: Sunday, May 26, 2013 8:17:51 AM

Joe

I was able to speak with SA Robertson this morning. Overall, I think we are very close. Just a few thoughts:

1. Please add a description of a preliminary forensic exam. Something like, conducted preliminary forensic

examinations on a number of pieces of evidence seized in this case. A preliminary examination is a high level
review taking no more than a couple hours, whereas a full forensic examination can take from one day to a full
week."

2. Paragraph 7d. Please add something to the effect of, did not note the machine's username."

3. Paragraph 7d. Please change the following sentence to: also reviewed the "user" files associated with account
resembling PFC Manning?s name and located several files containing text that was specifically referenced in the
chat logs received by U.S. Army CID during the initial phases of the investigation, though I did not specifically
note which text was referenced in chat logs."

4. Paragraph 7e. Please change this so it is consistent with the AIR, reviewed a file that appeared to contain
contact information for a member of the WikiLeaks Team. This contact information appeared to have been
produced and released by the WikiLeaks team and did not appear to be of a personal nature."

5. Paragraph 7f. Please change to, also found an archive file that contained approximately 11,000 sensitive and
classified documents, downloaded in Hyper Text Markup Language (HTML) format, though I did not note the
exact number."

6. Paragraph 7, generally. Most subparagraphs indicate, know this because I This could be
confusing because he specificlally states in paragraph four that the evidence was collected at FOB Hammer and
delivered to him at Camp Liberty. Not sure how to clarify this. Your thoughts?

Any issues, give me a call a?

Thanks,

Page 540 of 2169

01858

Josh



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Friday, May 24, 2013 11:23 AM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY (US)
Cc: Fein, Ashden MAJ USARMY MDW (US)

Subject: Robertson stipulation (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

Attached is the Calder Robertson stipulation. Let me know what you think as soon as you can. Are you still having
trouble reaching him? He has not been readily accessible on our end either, but we let him know (again) that you
wanted to speak with him. If I can facilitate further to wrap this up, let me know soon. Best time to reach out to
Germany would be about now.

CPT Joe Morrow

Trial Counsel

US. Army Military District of Washington



Classification: UNCLASSIFIED
Caveats: NONE

Page 541 of 2169

01859



From: ToomanI Joshua CPT USARMY (US)

To: in A MA ARMY MDW rr PT ARMY AMDW Angel
QPT LJSARMY (LJS)

Cc: Hurley, Thomas MAJ USARMY USARMY


Subject: RE: Struttmann Subpoena (UNCLASSIFIED)

Date: Sunday, May 26, 2013 6:46:59 AM

Sir

Cyber Agents did not receive the documents. Also, Trent noticed a couple errors.

1. Theiraddress

2. His last name is spelled Struttmann. Two on the end.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, May 24, 2013 5:02 PM

To: Tooman, Joshua CPT USARMY Morrow, oDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY
USARMY (US)

Subject: RE: Struttmann Subpoena (UNCLASSIFIED)

Josh,

We sent Mr. Struttman his subpoena and travel worksheet via certified mail

on 29 Apr 13. The tracking number is 7010 1060 001 1274 4460. We have not
received the return receipt. A copy is attached to this email. Please have

him let us know whether CyberAgents did not receive the documents.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, May 22, 2013 3:08 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY
USARMY (US)

Subject: Struttmann Subpoena (UNCLASSIFIED)

Page 542 of 2169

Classification: UNCLASSIFIED
Caveats: NONE
Sir

Could you all send a subpoena to Trent? Doing so will ensure a subsequent
subpoena for other cases doesn't slip in and complicate his presence.

Thanks,

Josh

Joshua J. Tooman
CPT, JA

Trial Defense Counsel

9990 Belvoir Drive

Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.

Classification: UNCLASSIFIED

Caveats: NONE

Page 543 of 2169

01860

01861



From: ToomanI Joshua CPT USARMY (US)

To: in A MA ARMY MDW rr PT ARMY AMDW Angel
QPT LJSARMY (L13)

Cc: Hurley, Thomas MAJ USARMY USARMY


Subject: RE: Struttmann Subpoena (UNCLASSIFIED)

Date: Saturday, May 25, 2013 7:54:23 PM

Thanks, sir.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, May 24, 2013 5:02 PM

To: Tooman, Joshua CPT USARMY Morrow, oDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY
USARMY (US)

Subject: RE: Struttmann Subpoena (UNCLASSIFIED)

Josh,

We sent Mr. Struttman his subpoena and travel worksheet via certified mail

on 29 Apr 13. The tracking number is 7010 1060 001 1274 4460. We have not
received the return receipt. A copy is attached to this email. Please have

him let us know Whether CyberAgents did not receive the documents.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, May 22, 2013 3:08 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY
USARMY (US)

Subject: Struttmann Subpoena (UNCLASSIFIED)

Classification: UNCLASSIFIED

Caveats: NONE

Sir

Could you all send a subpoena to Trent? Doing so will ensure a subsequent
subpoena for other cases doesn't slip in and complicate his presence.

Thanks,
Josh
Joshua J. Tooman

CPT, JA

Page 544 of 2169

01862

Trial Defense Counsel

9990 Belvoir Drive

Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.

Classification: UNCLASSIFIED

Caveats: NONE

Page 545 of 2169

01863









From: David Coombs

To: Fein. Ashden MAJ USARMY MDW (US): Whvte. Hunter CPT USARMY (US): Hurlev. Thomas MAJ USARMY
403); PT ARMY

Cc: USARMY (US): Morrow. JoDean (Joe) CPT USARMY USAMDW (US): Overgaard Angel
CPT USARMY (US): von Elten. Alexander (Alec) CPT USARMY (US): Mitroka. Katherine CPT USARMY (US):

USARMY (US)

Subject: Re: Stipulation of Expected Testimony

Date: Saturday, May 25, 2013 5:41:17 PM

Ashden,

That process works well when we are in the same area, however, having it in Word and using track changes is much
quicker when we're not. Please send a Word version.

Best,
David

-- Original message

From: "Fein, Ashden MAJ USARMY MDW

Date: 05/25/2013 4:50 PM
To: 'coombs armycourtmartialdefense.com'
USARMY




"Whyte, Hunter CPT
Hurley, Thomas MAJ USARMY
>,"Tooman, Joshua CPT USARMY
. USARMY
USARMY USAMDW














Morrow, oDean (Joe) CPT
Overgaard, Angel CPT USARMY

11 Elten, Alexander (Alec) CPT USARMY

'Mitroka, Katherine CPT USARMY

USARMY ms)

Subject: Re: Stipulation of Expected Testimony









David,

As we previously discussed regarding stips- we sent the so if the defense has any issues then we can quickly
reference defense requested changes without having to review the entire stip and keep moving the process along.
We are working on many stips at one time using the agreed upon list. Please send what ever changes you would
like so we can review just those changes and move on to the next stip.

Thank you.

Vr
Ashden

Original Message

From: David Coombs [m il rm i m]

Sent: Saturday, May 25, 2013 04:10 PM

To: Whyte, Hunter CPT USARMY Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka,
Katherine CPT USARMY USARMY Fein, Ashden MAJ USARMY MDW
(US)

Page 546 of 2169

Subject: RE: Stipulation of Expected Testimony
Please send me a Word version. Thank you.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Whyte, Hunter CPT USARMY (US)
Sent: Friday, May 24, 2013 6:36 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY von Elten, Alexander
(Alec) CPT USARMY Mitroka, Katherine CPT USARMY
- USARMY Fein, Ashden MAJ USARMY MDW

'coombs armycourtmartialdefense.com'

Subject: Stipulation of Expected Testimony

Gents,

Attached is a proposed stipulation of expected testimony for SSG Alejandro
Marin. As you know, SSG Marin is currently deployed and he is also one of
our first 25 witnesses. For that reason, can you please let us know your
thoughts on the attached stipulation, so everyone (especially his command in
theater) is on notice when we need to coordinate his travel for the
court-martial? Thank you!

Have a good weekend!

v/r
Hunter

Page 547 of 2169

01864

01865



From: Fein, Ashden MAJ USARMY MDW (US)

To: Wh PT ARMY Hurley, Thomas MAJ USARMY
PT ARMY

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: Re: Stipulation of Expected Testimony

Date: Saturday, May 25, 2013 4:50:27 PM

David,

As we previously discussed regarding stips- we sent the so if the defense has any issues then we can quickly
reference defense requested changes without having to review the entire stip and keep moving the process along.
We are working on many stips at one time using the agreed upon list. Please send what ever changes you would
like so we can review just those changes and move on to the next stip.

Thank you.

Vr
Ashden

Original Message

From: David Coombs [mailto:coombs armycourtmartialdefense.com]

Sent: Saturday, May 25, 2013 04:10 PM

To: Whyte, Hunter CPT USARMY Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka,
Katherine CPT USARMY USARMY Fein, Ashden MAJ USARMY MDW
(US)

Subject: RE: Stipulation of Expected Testimony

Please send me a Word version. Thank you.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is

Page 548 of 2169

01866



From: Whyte, Hunter CPT USARMY (US)
Sent: Friday, May 24, 2013 6:36 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY von Elten, Alexander
(Alec) CPT USARMY Mitroka, Katherine CPT USARMY
- USARMY Fein, Ashden MAJ USARMY MDW

'coombs armycourtmartialdefense.com'

Subject: Stipulation of Expected Testimony

Gents,

Attached is a proposed stipulation of expected testimony for SSG Alejandro
Marin. As you know, SSG Marin is currently deployed and he is also one of
our first 25 witnesses. For that reason, can you please let us know your
thoughts on the attached stipulation, so everyone (especially his command in
theater) is on notice when we need to coordinate his travel for the
court-martial? Thank you!

Have a good weekend!

V/r
Hunter

Page 549 of 2169

01867

From: David Coombs
To: Wh Hn PT ARMY ;Hr FMA ARMY mn PT ARMY
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel

CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY
USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: Stipulation of Expected Testimony
Date: Saturday, May 25, 2013 12:10:44 PM



Please send me a Word version. Thank you.

Best,
David

David E. Coombs, Esq.

Law Office of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282

coombs armycourtmartialdefense.com


>l<>l<>lcontain confidential attorney-client information and is intended for the
person(s) or company named. If you are not the intended recipient, please
notify the sender and delete all copies. Unauthorized disclosure, copying
or use of this information may be unlawful and is



From: Whyte, Hunter CPT USARMY
Sent: Friday, May 24, 2013 6:36 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)
Cc: USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY von Elten, Alexander
(Alec) CPT USARMY Mitroka, Katherine CPT USARMY
- USARMY Fein, Ashden MAJ USARMY MDW

'coombs armycourtmartialdefense.com'

Subject: Stipulation of Expected Testimony

Gents,

Attached is a proposed stipulation of expected testimony for SSG Alejandro
Marin. As you know, SSG Marin is currently deployed and he is also one of
our first 25 witnesses. For that reason, can you please let us know your
thoughts on the attached stipulation, so everyone (especially his command in
theater) is on notice when we need to coordinate his travel for the
court-martial? Thank you!

Have a good weekend!

v/r
Hunter

Page 550 of 2169

01868

Page 551 of2169

01869





From: Fein, Ashden MAJ USARMY MDW (US)

To: Tooman, Joshua QPT LJSARMY Morrow, ()gDean (Joe) QPT LJSARMY LJSAMDW Qvergaard, Angel
QPT LJSARMY (US)

Cc: Hurley, Thomas MAJ USARMY USARMY
.1le

Bee:
USARMY

Mitroka, Katherine CPT USARMY von Elten, Alexander (Alec) CPT USARMY

Whyte, Hunter CPT USARMY (US)

Subject: RE: Struttmann Subpoena (UNCLASSIFIED)

Date: Friday, May 24, 2013 5:02:00 PM

Attachments: Struttman - letterpdf


Josh,

We sent Mr. Struttman his subpoena and travel worksheet via certified mail

on 29 Apr 13. The tracking number is 7010 1060 001 1274 4460. We have not
received the return receipt. A copy is attached to this email. Please have

him let us know Whether CyberAgents did not receive the documents.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, May 22, 2013 3:08 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY

USAMDW Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY
USARMY (US)

Subject: Struttmann Subpoena (UNCLASSIFIED)

Classification: UNCLASSIFIED

Caveats: NONE

Sir

Could you all send a subpoena to Trent? Doing so will ensure a subsequent
subpoena for other cases doesn?t slip in and complicate his presence.

Thanks,

Josh

Joshua J. Tooman
CPT, A

Trial Defense Counsel
9990 Belvoir Drive

Fort Belvoir, VA 22060

Page 552 of 2169

01870





This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy

Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.

Classification: UNCLASSIFIED

Caveats: NONE

Page 553 of 2169

01871

From: Tooman, Joshua CPT USARMY (US)

To: Morrow, ,JQDgan (Joe) QPT LJSARMY LJSAMDW r Th MA ARMY
Cc: Fein, Ashden MAJ USARMY MDW
Subject: RE: Robertson stipulation (UNCLASSIFIED)

Date: Friday, May 24, 2013 11:34:05 AM



Classification: UNCLASSIFIED
Caveats: NONE

Thanks, Joe. I am still having trouble reaching him. We've exchanged a
couple emails, but every time I call his DSN there is no answer.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Friday, May 24, 2013 11:23 AM

To: Tooman, Joshua CPT USARMY Hurley, Thomas MAJ USARMY (US)
Cc: Fein, Ashden MAJ USARMY MDW (US)

Subject: Robertson stipulation (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

Josh,

Attached is the Calder Robertson stipulation. Let me know what you think as
soon as you can. Are you still having trouble reaching him? He has not
been readily accessible on our end either, but we let him know (again) that
you wanted to speak with him. If I can facilitate further to wrap this up,

let me know soon. Best time to reach out to Germany would be about now.

Page 554 of 2169

CPT Joe Morrow

Trial Counsel

US. Army Military District of Washington



Classification: UNCLASSIFIED
Caveats: NONE

Classification: UNCLASSIFIED
Caveats: NONE

Page 555 of 2169

01872

01873

From: Tooman, Joshua CPT USARMY (US)

To: Fain, MAJ LJSARMY MDW rr PT ARMY AMDW g2vgrgaard, Angel
QPT LJSARMY (L15)

Cc: Hurley, Thomas MAJ USARMY USARMY
1&1

Subject: Struttmann Subpoena (UNCLASSIFIED)

Date: Wednesday, May 22, 2013 3:07:37 PM



Classification: UNCLASSIFIED
Caveats: NONE
Sir

Could you all send a subpoena to Trent? Doing so will ensure a subsequent subpoena for other cases doesn?t slip in
and complicate his presence.

Thanks,

Josh

Joshua J. Tooman
CPT, JA

Trial Defense Counsel

9990 Belvoir Drive

Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or attorney-client communication or may be
protected by another privilege recognized under the law. Do not distribute, forward, or release Without the prior
approval of the sender. In addition, this communication may contain individually identifiable information the
disclosure of Which, to any person or agency not entitled to receive it, is or may be prohibited by the Privacy Act, 5
U.S.C. ?5 52a. Improper disclosure of protected information could result in civil action or criminal prosecution.

Classification: UNCLASSIFIED

Caveats: NONE

Page 556 of 2169

01874





From: Tooman Joshua CPT USARMY (US)

To: Morrow. JoDean (Joe) CPT USARMY USAMDW (US): Fein. Ashden MAJ USARMY MDW (US): Qvergaarq Angel
QPT USARMY (LJS)

Cc: David E. Coombs; Hurlev. Thomas MAJ USARMY (US)

Subject: RE: SA Robertson (UNCLASSIFIED)

Date: Wednesday, May 22,2013 10:54:46 AM



Classification: UNCLASSIFIED
Caveats: NONE

Roger, thanks.

Joshua J. Tooman

CPT, A

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



This communication may be privileged as attorney work product and/or
attorney-client communication or may be protected by another privilege
recognized under the law. Do not distribute, forward, or release Without the
prior approval of the sender. In addition, this communication may contain
individually identifiable information the disclosure of Which, to any person
or agency not entitled to receive it, is or may be prohibited by the Privacy
Act, 5 U.S.C. ?552a. Improper disclosure of protected information could
result in civil action or criminal prosecution.



From: Morrow, oDean (Joe) CPT USARMY USAMDW (US)

Sent: Wednesday, May 22, 2013 10:48 AM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW
Overgaard, Angel CPT USARMY (US)

Cc: David E. Coombs; Hurley, Thomas MAJ USARMY (US)

Subject: RE: SA Robertson (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: NONE

No, there shouldn't be any classified information.
CPT Joe Morrow

Trial Counsel
US. Army Military District of Washington





From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, May 22, 2013 10:40 AM

To: Morrow, oDean (Joe) CPT USARMY USAMDW Fein, Ashden MAJ USARMY

Page 557 of 2169

01875



INSTRUCTIONS FOR PREPARING AND ARRANGING RECORD OF TRIAL





USE OF FORM Use this form and MOM, 1984,
Appendix 14, will be used by the trial counsel and
the reporter as a guide to the preparation of the
record of trial in general and special court?martial
cases in which a verbatim record is prepared. Air
Force uses this form and departmental
instructions as a guide to the preparation of the
record of trial in general and special court?martial
cases in which a summarized record is authorized.
Army and Navy use DD Form 491 for records of
trial in general and special court?martial cases in
which a summarized record is authorized.
lnapplicable words of the printed text will be
deleted.

COPIES See MOM, 1984, RCM 1103(g). The
convening authority may direct the preparation of
additional copies.

ARRANGEMENT When forwarded to the
appropriate Judge Advocate General or for judge
advocate review pursuant to Article 64(a), the
record will be arranged and bound with allied
papers in the sequence indicated below. Trial
counsel is responsible for arranging the record as
indicated, except that items 6, 7, and 15e will be
inserted by the convening or reviewing authority,
as appropriate, and items 10 and 14 will be
inserted by either trial counsel or the convening or
reviewing authority, whichever has custody of
them.

1. Front cover and inside front cover (chronology
sheet) of DD Form 490.

2. Judge advocate's review pursuant to Article
64(a), if any.

3. Request of accused for appellate defense
counsel, or waiver/withdrawal of appellate rights,
if applicable.

4. Briefs of counsel submitted after trial, if any
(Article

5. DD Form 494, "Court?Martial Data Sheet."

6. Court?martial orders promulgating the result of
trial as to each accused, in 10 copies when the
record is verbatim and in 4 copies when it is
summarized.

7. When required, signed recommendation of
staff judge advocate or legal officer, in duplicate,
together with all clemency papers, including
clemency recommendations by court members.



8. Matters submitted by the accused pursuant to
Article 60 (MOM, 1984, RCM 1105).

9. DD Form 458, "Charge Sheet" (unless included
at the point of arraignment in the record).

10. Congressional inquiries and replies, if any.

11. DD Form 457, "Investigating Officer's Report,"
pursuant to Article 32, if such investigation was
conducted, followed by any other papers which
accompanied the charges when referred for trial,
unless included in the record of trial proper.

12. Advice of staff judge advocate or legal officer,
when prepared pursuant to Article 34 or otherwise.

13. Requests by counsel and action of the
convening authority taken thereon requests
concerning delay, witnesses and depositions).

14. Records of former trials.
15. Record of trial in the following order:
a. Errata sheet, if any.

b. lndex sheet with reverse side containing
receipt of accused or defense counsel for copy of
record or certificate in lieu of receipt.

c. Record of proceedings in court, including
Article 39(a) sessions, if any.

d. Authentication sheet, followed by certificate
of correction, if any.

e. Action of convening authority and, if appro?
priate, action of officer exercising general court?
martial jurisdiction.

f. Exhibits admitted in evidence.

g. Exhibits not received in evidence. The page
of the record of trial where each exhibit was
offered and rejected will be noted on the front of
each exhibit.

h. Appellate exhibits, such as proposed in?
structions, written offers of proof or preliminary
evidence (real or documentary), and briefs of
counsel submitted at trial.



DD FORM 490, MAY 2000

Inside of Back Cover



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