Title: Volume FOIA 009

Release Date: 2014-03-20

Text: 02540



Volume 9 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, 17?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DD FORM 490, MAY 2000 PREVIOUS EDITION IS OBSOLETE Front Cover



02541

Sent: Wednesday, February 13, 2013 10:47 AM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Angel,

Thank you for getting back to me on this in a timely manner. I accepted all
of the changes except for the "limited purposes of the motion" language. I
eliminated this language because the stip of expected testimony is not for
the purposes of the motion. It is my understand that COL Lind has already
determined that Mr. - would be relevant. However, due to his
concerns about being associated with the case, she wanted us to see if we
could enter into a stip of expected testimony. If I am wrong about this,
you obviously can still object to the relevance of Mr. - In other
words, entering into a stip of expected testimony does not admit to the
relevance or the admissibility of the information contained in the stip.

Let me know if you have any issues with this COA.

Best,

David

David E. Coombs, Esq.

Law Of?ce 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 1218 of2169

02542

Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Overgaard, Angel CPT USARMY (US)



Sent: Wednesday, February 13, 2013 9:28 AM

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

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE

David,

I made a couple minor changes, which I think more accurately re?ect what
Mr. - would say. In addition, I added that the Stipulation was for
the limited purpose of the defense motion. Please let me know if you have
any issues with the changes. Thank you!

VR

ANGEL M. OVERGAARD

Page 1219 of2169

CPT, JA
Trial Counsel, MDW

Fort McNair, DC


From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, February 08, 2013 3:38 PM

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

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

- USARMY (US)

Subject: RE: Stip of Expected Testimony

David,

Angel is traveling right now. We received the information and she will get
back to you. Thank you.

v/r

Ashden



From: David Coombs [m il rm i



Sent: Friday, February 08, 2013 3:02 PM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY USARMY (US)

Page 1220 of 2169

02543

Subject: Stip of Expected Testimony
Angel,

I have attached a stipulation of expected testimony based upon our
conversation with% - and the late st version of his declaration.

Although! . - con?rmed the facts regarding_ and CPT
Tooman's second RFI during our conversation, I have attached the relevant

email as additional support for your bene?t. Let me know if you have any
questions.

Best,

David

David E. Coombs, Esq.

Law Of?ce 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






Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Page 1221 of2169

02544

02545

Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1222 of 2169

02546



From: David E. Coombs

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


Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Date: Friday, February 22, 2013 1:30:06 PM

Angel,

I think your proposed changes sound fair. However, I think we should tweak the language to be consistent within
the paragraph. Your last sentence says ?either? meaning that to his knowledge CALL was not tasked to conduct a
rapid adaption process or a detailed case study. What do you think of the following:

8. Although CALL is the center for the Army's lessons learned, each unit or major command has the ability to
capture its own lessons learned without sharing that information with CALL. To my knowledge, CALL was not
asked to perform a rapid adaption process in this case. If CALL was not asked to perform a rapid adaption process
in this case, it was because either the information leaked did not warrant a rapid adaption response or the Army
eliminated the need for a rapid adaption process by taking immediate steps to address any issues presented by the
leaks. If a rapid adaption was not requested, CALL could have also completed a detailed case study. To my
knowledge, CALL was not asked to complete a detailed case study on the leaks in this case either.

If this above look good, then I am ?ne with signing the statement.

Best,

David



From: Overgaard, Angel CPT USARMY

Sent: Friday, February 22, 2013 12:55 PM

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

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT
USARMY USARMY (US)

Subject: RE: Stip 0f Expected Testimony (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE

Page 1223 of 2169

02547

David,

I see your point in distinguishing between the rapid adaption process and the detailed case study. What if we just
eliminate the timing portion? I think that would also eliminate the need to call Mr. - again.

Below, I deleted the timing portions and added the standard language that Mr. - found acceptable not
de?nitively knowing whether or not CALL was asked to do any work or in fact did perform any work).

8. Although CALL is the center for the Army's lessons learned, each unit or major command has the ability to
capture its own lessons learned without sharing that information with CALL. If CALL was not asked to perform a
rapid adaption process in this case, I do not know the reason. It is possible that if CALL did not perform a rapid
adaption process in this case, it was because either the information leaked did not warrant a rapid adaption response
or the Army eliminated the need for a rapid adaption process by taking immediate steps to address any issues
presented by the leaks. If a rapid adaption was not requested, CALL could have also completed a detailed case
study. To my knowledge, CALL was not asked to complete a detailed case study on the leaks in this case either.

Please let me know if this is acceptable. If so, I will paste it in, sign it, and send it to you. Thank you.

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Fort McNair, DC



From: David E. Coombs com


Sent: Friday, February 22, 2013 11:21 AM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY (US)

Page 1224 of 2169

02548

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Angel,

I think we are close.

Mr. - did agree that it was possible that "If CALL did not perform a rapid adaption process, it may have been
because the Army immediately addressed the issue of the leaks after they happened." He made this statement in a
response to one of your questions. As such, I think it is fair to add this to the stipulation.

I do have some issues with the other additions as I believe that they give a false impression of what the actual facts
are and what Mr. - would testify to if called as a witness:

1) is just one of the many sources for lessons learned in the Army."
CALL (Center for Army Lessons Learned) is the source for lessons learned in
the Army. Obviously, each unit may also do a lessons learned on their own

if they wish. If that is what you are aiming for, I would not object to including something along the lines that
"although CALL is the source for lessons learned in the Army, each unit or major command has the ability to
capture its own lessons learned."

2) "It takes several months to complete a CALL study." While this may be true, this does not comport with what
Mr. - would testify to about a rapid adaption process. The rapid adaption process is separate from a CALL
case study. Mr. - would testify that the rapid adaption process does not take several months to complete.

Given the above, I would agree to the following:

8. Although CALL is the center for the Army's lessons learned, each unit or major command has the ability to
capture its own lessons learned without sharing that information with CALL. I do not know why CALL was not
asked to perform a rapid adaption process in this case. It is possible that CALL did not perform a rapid adaption
process in this case because either the information leaked did not warrant a rapid adaption response or the Army
eliminated the need for a rapid adaption process by taking immediate steps to address any issues presented by the
leaks. If CALL had been requested to complete a rapid adaption process, this could have been completed by CALL
in a matter of days or weeks. If a rapid adaption was not requested, CALL could have also competed a detailed
case study. A detailed case study can take several months to complete. To my knowledge, CALL was not asked to
complete a detailed case study on the leaks in this case either.

Page 1225 of 2169

02549

Let me know what you think about the above. I do not object to another conference call with Mr. - if you
believe one is necessary.

Best,

David



From: Overgaard, Angel CPT USARMY

Sent: Friday, February 22, 2013 9:56 AM
To: 'David Coombs'; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE
David,

We initially reviewed the Stipulation with the view that it was going to be used in support of the defense motion, not
that it was going to potentially be used at trial. Upon a secondary review with the view that the Stipulation would
potentially being admissible at trial, we added a couple of lines to include what we would potentially elicit on cross
examination if Mr.

was called during the merits or sentencing. I think the additions were discussed during our phone call with
Mr. We will sign the attached Stipulation if it is agreeable to the defense. The additions are tracked.
Please let me know if you have any issues with the additions. Thank you.

VR

Angel

Page 1226 of 2169

02550

ANGEL M. OVERGAARD
CPT, JA
Trial Counsel, MDW

Fort McNair, DC



From: David Coombs


Sent: Wednesday, February 13, 2013 10:47 AM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Angel,

Thank you for getting back to me on this in a timely manner. I accepted all of the changes except for the "limited
purposes of the motion" language. I eliminated this language because the stip of expected testimony is not for the
purposes of the motion. It is my understand that COL Lind has already determined that Mr. - would be
relevant. However, due to his concerns about being associated with the case, she wanted us to see if we could enter
into a stip of expected testimony. If I am wrong about this, you obviously can still object to the relevance of Mr.

In other words, entering into a stip of expected testimony does not admit to the relevance or the
admissibility of the information contained in the stip.

Let me know if you have any issues with this COA.

Best,

David

David E. Coombs, Esq.

Page 1227 of 2169

02551

Law Of?ce 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





Notice: This transmission, including attachments, may contain con?dential attomey-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: Overgaard, Angel CPT USARMY

Sent: Wednesday, February 13, 2013 9:28 AM
To: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT

USARMY USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE

David,

Page 1228 of 2169

02552

I made a couple minor changes, which I think more accurately re?ect what Mr. - would say. In addition, I
added that the Stipulation was for the limited purpose of the defense motion. Please let me know if you have any
issues with the changes. Thank you!

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Fort McNair, DC


From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, February 08, 2013 3:38 PM

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

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

Subject: RE: Stip of Expected Testimony

David,

Angel is traveling right now. We received the information and she will get back to you. Thank you.

v/r

Ashden



From: David Coombs


Page 1229 of 2169

02553

Sent: Friday, February 08, 2013 3:02 PM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) 111 CPT USARMY USAMDW Whyte,

Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: Stip of Expected Testimony
Angel,

I have attached a stipulation of expected testimony based upon our conversation with% - and the latest
version of his declaration.

Althoughg - con?rmed the facts regarding- and CPT Tooman's second RFI during our
I have attached the relevant email as additional support for your bene?t. Let me know if you have
any questions.

conversa

Best,

David

David E. Coombs, Esq.

Law Of?ce 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

ch>



Notice: This transmission, including attachments, may contain con?dential attomey-client
information and is intended for the

Page 1230 of 2169

02554

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

Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED

Caveats: NONE

Page 1231 of2169

02555



From: David E. Coombs

To: QVergaard, Angel QPT LJSARMY Hurley, Thomas MAJ LJSARMY TQQman, (Joshua ,1 QPT LJSARMY


Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Date: Friday, February 22, 2013 11:22:29 AM

Angel,

I think we are close.

Mr. - did agree that it was possible that "If CALL did not perform a
rapid adaption process, it may have been because the Army immediately
addressed the issue of the leaks after they happened." He made this
statement in a response to one of your questions. As such, I think it is

fair to add this to the stipulation.

I do have some issues with the other additions as I believe that they give a
false impression of what the actual facts are and what Mr. - would
testify to if called as a witness:

1) is just one of the many sources for lessons learned in the Army."
CALL (Center for Army Lessons Learned) is the source for lessons learned in
the Army. Obviously, each unit may also do a lessons learned on their own
if they wish. If that is what you are aiming for, I would not object to
including something along the lines that "although CALL is the source for
lessons learned in the Army, each unit or major command has the ability to
capture its own lessons learned."

2) "It takes several months to complete a CALL study." While this may be
true, this does not comport with what Mr. - would testify to about a
rapid adaption process. The rapid adaption process is separate from a CALL
case study. Mr. - would testify that the rapid adaption process does
not take several months to complete.

Given the above, I would agree to the following:

8. Although CALL is the center for the Army's lessons learned, each unit or
major command has the ability to capture its own lessons learned without
sharing that information with CALL. I do not know why CALL was not asked to
perform a rapid adaption process in this case. It is possible that CALL did

not perform a rapid adaption process in this case because either the

information leaked did not warrant a rapid adaption response or the Army
eliminated the need for a rapid adaption process by taking immediate steps

to address any issues presented by the leaks. If CALL had been requested to
complete a rapid adaption process, this could have been completed by CALL in
a matter of days or weeks. If a rapid adaption was not requested, CALL

could have also competed a detailed case study. A detailed case study can

take several months to complete. To my knowledge, CALL was not asked to
complete a detailed case study on the leaks in this case either.

Let me know what you think about the above. I do not object to another
conference call with Mr. - if you believe one is necessary.

Page 1232 of 2169

02556

Best,
David


From: Overgaard, Angel CPT USARMY (US)

Sent: Friday, February 22, 2013 9:56 AM

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

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

David,

We initially reviewed the Stipulation with the view that it was going to be
used in support of the defense motion, not that it was going to potentially

be used at trial. Upon a secondary review with the view that the Stipulation
would potentially being admissible at trial, we added a couple of lines to
include what we would potentially elicit on cross examination if Mr.
- was called during the merits or sentencing. I think the additions
were discussed during our phone call with Mr. - We will sign the
attached Stipulation if it is agreeable to the defense. The additions are
tracked. Please let me know if you have any issues with the additions. Thank
you.

VR
Angel

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Fort McNair, DC



From: David Coombs [m il rm i

Sent: Wednesday, February 13, 2013 10:47 AM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Angel,

Thank you for getting back to me on this in a timely manner. I accepted all
of the changes except for the "limited purposes of the motion" language. I

Page 1233 of 2169

eliminated this language because the stip of expected testimony is not for
the purposes of the motion. It is my understand that COL Lind has already
determined that Mr. - would be relevant. However, due to his
concerns about being associated with the case, she wanted us to see if we
could enter into a stip of expected testimony. If I am wrong about this,
you obviously can still object to the relevance of Mr. - In other
words, entering into a stip of expected testimony does not admit to the
relevance or the admissibility of the information contained in the stip.

Let me know if you have any issues with this COA.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Sent: Wednesday, February 13, 2013 9:28 AM

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

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

David,

I made a couple minor changes, which I think more accurately re?ect what
Mr. - would say. In addition, I added that the Stipulation was for
the limited purpose of the defense motion. Please let me know if you have
any issues with the changes. Thank you!

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Page 1234 of 2169

02557

02558

Fort McNair, DC



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, February 08, 2013 3:38 PM

To: David Coombs; Overgaard, Angel CPT USARMY Hurley, Thomas MAJ

USARMY Tooman, Joshua CPT USARMY (US)

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

USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony

David,

Angel is traveling right now. We received the information and she will get
back to you. Thank you.

v/r

Ashden



From: David Coombs [m il rm i

Sent: Friday, February 08, 2013 3:02 PM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY USARMY (US)

Subject: Stip of Expected Testimony
Angel,

I have attached a stipulation of expected testimony based upon our
conversation with and the latest version of his declaration.
AlthoughF. con?rmed the facts regarding_ and CPT
Tooman's second I during our conversation, I have attached the relevant
email as af?litional support for your bene?t. Let me know if you have any
questions.





Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential attomey-client information and is intended for the

Page 1235 of 2169

02559

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 prohibited.

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1236 of 2169

02560



From: ACMD
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, 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: BM Travel
Date: Wednesday, February 20, 2013 4:28:01 PM
Ashden,

That works for me.

Best,
David



From: Fein, Ashden MAJ USARMY MDW
Sent: Wednesday, February 20, 2013 4: 19 PM

To: ACMD

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, 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: BM Travel
David,

That schedule works and we will support it. We will also have classi?ed
binders ready that morning with all the charged documents, separated by
dataset/ speci?cation. We intend to have them marked as appellate exhibits
that way he could review them and be able to reference them with the Court.
They will have BATES numbers on them. If you would like to review them
Monday afternoon, we can have them available ahead of time.

v/r

Ashden



From: ACMD [mailtozcoombs arm courtmartialdefensecom]

Sent: Wednesday, February 20, 2013 4:13 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

Morrow, 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: BM Travel

Ashden,

We will need to meet with him in order to have him review the charged
documents again. This is something that we could likely do towards the end

of the day on Tuesday. I recommend that we go as planned, but then break
for the day around 1500. How does that sound to you? BTW, are we starting

Page 1237 of 2169

02561

at 0900 or 1000?

Best;
David



From: Fein; Ashden MAJ USARMY MDW
Sent: Wednesday, February 20; 2013 3:50 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman; Joshua CPT USARMY
Morrow; 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: BM Travel

David,

Good afternoon. Due to the expected weather going down tomorrow at Fort
Leavenworth; US Army transportation will not be able to ?y BM until Monday
morning. If you still need time to meet with him prior to the hearing; we

will not object to starting our session later on Tuesday.

v/r

Ashden

Page 1238 of 2169

02562

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

MDW CIV (US)
Subject: RE: BM Travel
Date: Wednesday, February 20, 2013 4:19:00 PM
David,

That schedule works and we will support it. We will also have classi?ed binders ready that morning with all the
charged documents, separated by dataset/ speci?cation. We intend to have them marked as appellate exhibits that
way he could review them and be able to reference them with the Court. They will have BATES numbers on them.
If you would like to review them Monday afternoon, we can have them available ahead of time.

v/r

Ashden



From: ACMD [mailtozcoombs arm courtmartialdefensecom]

Sent: Wednesday, February 20, 2013 4:13 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, 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: BM Travel
Ashden,

We will need to meet with him in order to have him review the charged
documents again. This is something that we could likely do towards the end
of the day on Tuesday. I recommend that we go as planned, but then break
for the day around 1500. How does that sound to you? BTW, are we starting
at 0900 or 1000?

Best,
David



From: Fein, Ashden MAJ USARMY MDW
Sent: Wednesday, February 20, 2013 3:50 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, 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: BM Travel
David,

Good afternoon. Due to the expected weather going down tomorrow at Fort

Page 1239 of 2169

02563

Leavenworth, US Army transportation will not be able to ?y BM until Monday
morning. If you still need time to meet with him prior to the hearing, we
will not object to starting our session later on Tuesday.

V/r

Ashden

Page 1240 of 2169

02564



From: ACMD
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, 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: BM Travel
Date: Wednesday, February 20, 2013 4:13:46 PM
Ashden,

We will need to meet with him in order to have him review the charged
documents again. This is something that we could likely do towards the end
of the day on Tuesday. I recommend that we go as planned, but then break
for the day around 1500. How does that sound to you? BTW, are we starting
at 0900 or 1000?

Best,
David



From: Fein, Ashden MAJ USARMY MDW
Sent: Wednesday, February 20, 2013 3:50 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, 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: BM Travel

David,

Good afternoon. Due to the expected weather going down tomorrow at Fort
Leavenworth, US Army transportation will not be able to ?y BM until Monday
morning. If you still need time to meet with him prior to the hearing, we

will not object to starting our session later on Tuesday.

v/r

Ashden

Page 1241 of2169

02565







From: Fein, Ashden MAJ USARMY MDW (US)

To: vi

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, 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: USARMY USAMDW

MDW CIV (US)

Subject: BM Travel

Date: Wednesday, February 20, 2013 3:49:00 PM

David,

Good afternoon. Due to the expected weather going down tomorrow at Fort Leavenworth, US Army transportation
will not be able to ?y BM until Monday morning. If you still need time to meet with him prior to the hearing, we
will not object to starting our session later on Tuesday.

V/r

Ashden

Page 1242 of 2169

02566

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas MAJ 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 USARMY (US)
Subject: RE: New CMCO
Date: Tuesday, February 19, 2013 11:59:46 AM



Ashden,
Thank you for the clari?cation.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Tuesday, February 19, 2013 11:53 AM

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
USARMY (US)

Subject: RE: New CMCO

David,

I just veri?ed that (2012) was an of?cer panel selected for a very senior of?cer who outranked all the
panel members on (2012).

v/r

Ashden



From: David Coombs [m il rm i

Sent: Tuesday, February 19, 2013 11:26 AM

To: Fein, Ashden MAJ USARMY MDW 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
USARMY (US)

Page 1243 of 2169

02567

Subject: RE: New CMCO
Ashden,

I already have this CMCO. I was confused by the new CMCO #1 which states at the top that CMCO #3 was the last
in the series for 2012. Given your response, I imagine CMCO #3 did not amend CMCO #2 for 2012.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Tuesday, February 19, 2013 11:10 AM

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
USARMY (US)

Subject: FW: New CMCO

David,

You requested CMCO #3 (2012) but I am not aware of one that would apply to this case. Please see below for
CMCO #2 (2012) which applied to this case and is superseded by CMCO #1 (2013).

v/r

Ashden



From: Fein, Ashden CPT USA JFHQ-NCIUMDW SJA

Sent: Wednesday, February 22, 2012 6: 19 PM

To: Lind, Denise COL USARMY (US)

Cc: Morrow JoDean, CPT USA JFHQ-NCIUMDW Overgaard, Angel M. CPT USA JFHQ-NCIUMDW
Bouchard, Paul CPT USARMY Whyte, Jeffrey H. CPT USA JFHQ-NCIUMDW Ford, Arthur
D?g USA JFHQ-NCIUMDW Matthew kemkes; Tooman, Joshua
USARMY USARMY
USA JFHQ-NCIUMDW
USA JFHQ-NCIUMDW CIV JFHQ-NCIUMDW
NCIUMDW Hall Cassius Mr FMMC Ganiel, Charles CIV Lillian Smith
Subject: New CMCO














CIV JFHQ-

Page 1244 of 2169

02568

COL Lind,

Good evening. The prosecution just received the newest convening order (CMCO 2, 22 Feb 12-attached). As you
will see, this order supersedes the previous order and United States will ensure this is re?ected in the script.

v/r
CPT Fein

Page 1245 of 2169

02569

From: Fein, Ashden MAJ USARMY MDW (US)
To: "David r 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 USARMY (US)
Subject: RE: New CMCO
Date: Tuesday, February 19, 2013 11:39:00 AM



David,
I will verify that (2012) did not amend (2012), but we were tracking that it did not.

V/r
Ashden



From: David Coombs [m il rm i

Sent: Tuesday, February 19, 2013 11:26 AM

To: Fein, Ashden MAJ USARMY MDW 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
USARMY (US)

Subject: RE: New CMCO

Ashden,

I already have this CMCO. I was confused by the new CMCO #1 which states at the top that CMCO #3 was the last
in the series for 2012. Given your response, I imagine CMCO #3 did not amend CMCO #2 for 2012.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may contain con?dential 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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Tuesday, February 19, 2013 11:10 AM

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

USARMY (US)

Page 1246 of 2169

02570

Subject: FW: New CMCO
David,

You requested CMCO #3 (2012) but I am not aware of one that would apply to
this case. Please see below for CMCO #2 (2012) which applied to this case and
is superseded by CMCO #1 (2013).

v/r

Ashden



From: Fein, Ashden CPT USA JFHQ-NCIUMDW SJA

Sent: Wednesday, February 22, 2012 6:19 PM

To: Lind, Denise COL USARMY (US)

Cc: Morrow JoDean, CPT USA JFHQ-NCIUMDW Overgaard, Angel M. CPT USA
JFHQ-NCIUMDW Bouchard, Paul CPT USARMY Whyte, Jeffrey H. CPT USA
JFHQ-NCIUMDW Ford, Arthur D. USA JFHQ-NCIUMDW
tthew kemkes; Tooman, Joshua CPT

USARMY USARMY
USA JFHQ-NCIUMDW
USA JFHQ-NCIUMDW CIV
JFHQ-NCIUMDW CIV JFHQ-NCIUMDW Hall Cassius Mr
FMMC Ganiel, Charles CIV Lillian Smith

Subject: New CMCO







COL Lind,
Good evening. The prosecution just received the newest convening order (CMCO
2, 22 Feb l2-attached). As you will see, this order supersedes the previous

order and United States will ensure this is re?ected in the script.

v/r
CPT Fein

Page 1247 of 2169

02571

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas MAJ LJSARMY Tooman, Joshua ,1 QPT LJSARMY
.05).

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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: New CMCO
Date: Tuesday, February 19, 2013 11:26:06 AM



Ashden,

I already have this CMCO. I was confused by the new CMCO #1 which states at the top that CMCO #3 was the last
in the series for 2012. Given your response, I imagine CMCO #3 did not amend CMCO #2 for 2012.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Tuesday, February 19, 2013 11:10 AM

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
USARMY (US)

Subject: FW: New CMCO

David,

You requested CMCO #3 (2012) but I am not aware of one that would apply to
this case. Please see below for CMCO #2 (2012) which applied to this case and
is superseded by CMCO #1 (2013).

v/r

Ashden



From: Fein, Ashden CPT USA JFHQ-NCIUMDW SJA

Sent: Wednesday, February 22, 2012 6: 19 PM

To: Lind, Denise COL USARMY (US)

Cc: Morrow JoDean, CPT USA JFHQ-NCIUMDW Overgaard, Angel M. CPT USA

Page 1248 of 2169

02572

JFHQ-NCIUMDW Bouchard; Paul CPT USARMY Whyte; Jeffrey H. CPT USA

JFHQ-NCIUMDW Ford, Arthur D. USA JFHQ-NCIUMDW

tthew kemkes; Tooman; Joshua CPT

USARMY USARMY

USA JFHQ-NCIUMDW
USA JFHQ-NCIUMDW CIV

JFHQ-NCIUMDW CIV JFHQ-NCIUMDW Hall Cassius Mr

FMMC Ganiel; Charles CIV Lillian Smith

Subject: New CMCO





9

COL Lind;
Good evening. The prosecution just received the newest convening order (CMCO
2; 22 Feb 12-attached). As you will see, this order supersedes the previous

order and United States will ensure this is re?ected in the script.

v/r
CPT Fein

Page 1249 of 2169

02573






From: Fein, Ashden MAJ USARMY MDW (US)

To: David ?429ng Th MA ARMY Tooman, Joshua ,1 QPT LJSARMY (L15)

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

Bcc:

Mitroka, Katherine

CPT USARMY (US)

Subject: FW: New CMCO

Date: Tuesday, February 19, 2013 11:10:00 AM

Attachments: CMCO 2 General CM 2012.9df

David,

You requested CMCO #3 (2012) but I am not aware of one that would apply to
this case. Please see below for CMCO #2 (2012) which applied to this case and
is superseded by CMCO #1 (2013).

v/r
Ashden



From: Fein, Ashden CPT USA JFHQ-NCIUMDW SJA

Sent: Wednesday, February 22, 2012 6: 19 PM

To: Lind, Denise COL USARMY (US)

Cc: Morrow JoDean, CPT USA JFHQ-NCIUMDW Overgaard, Angel M. CPT USA

JFHQ-NCIUMDW Bouchard, Paul CPT USARMY Whyte, Jeffrey H. CPT USA

JFHQ-NCIUMDW Ford, Arthur D. USA JFHQ-NCIUMDW

tthew kemkes; Tooman, Joshua CPT

USARMY USARMY

USA JFHQ-NCIUMDW
USA JFHQ-NCIUMDW Ms CIV

JFHQ-NCIUMDW CIV JFHQ-NCIUMDW Hall Cassius Mr

FMMC Ganiel, Charles CIV Lillian Smith

Subject: New CMCO












9



COL Lind,
Good evening. The prosecution just received the newest convening order (CMCO
2, 22 Feb 12-attached). As you will see, this order supersedes the previous

order and United States will ensure this is re?ected in the script.

v/r
CPT Fein

Page 1250 of 2169

02574

From: David Coombs

To: in A MA ARMY MDW Hurley, Thomas MAJ LJSARMY ngman, Joshua ,1 QPT LJSARMY
.05).

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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: CMCO #3 for 2012
Date: Tuesday, February 19, 2013 10:08:50 AM



Ashden,
Could you please send me CMCO #3 for 2012? Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may contain con?dential attomey-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 prohibited.

Page 1251 of2169

02575



From: ToomanI Joshua CPT USARMY (US)

To: vr An IM PT ARMY

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: [External] FW: Secured VTC request (UNCLASSIFIED)

Date: Thursday, February 14, 2013 4:03:43 PM

Thanks, Angel



From: Overgaard, Angel CPT USARMY (US)

Sent: Thursday, February 14, 2013 4:03 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: FW: [External] FW: Secured VTC request (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Josh,
I sent the below email to Tom Hoskins, so he is tracking for both of us on Tuesday.

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Fort McNair, DC



From: Overgaard, Angel CPT USARMY (US)

Sent: Thursday, February 14, 2013 4:01 PM

To: Hoskins, Thomas CTR (US)

Cc: Hoskins, Thomas LT USN Fein, Ashden MAJ USARMY MDW
USARMY (US)

Subject: RE: [External] FW: Secured VTC request (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Tom,

Josh Tooman and I coordinated. We have reserved 1000-1130EST to speak with you and then the defense will speak
with you from 1130-1300EST. You will be able to conduct both from NORTHCOM. Thank you, and we
will speak with you Tuesday.

Safe travels.

VR
Angel

ANGEL M. OVERGAARD

Page 1252 of 2169

02576

CPT, JA
Trial Counsel, MDW
Fort McNair, DC



From: Hoskins, Thomas

Sent: Wednesday, February 13, 2013 9:07 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hoskins, Thomas LT USN Hall, Cassius CIV David Coombs;
Overgaard, Angel CPT USARMY (US)

Subject: Re: [External] FW: Secured VTC request (UNCLASSIFIED)

Josh:

Can you coordinate with CPT Angel Overgaard on the prosecuting side? I must SVTC with her before I chat with
you.

Best-
Tom

Sent from my iPhone

On Feb 13, 2013, at 1:51 PM, "Tooman, Joshua CPT USARMY wrote:

Classi?cation: UNCLASSIFIED

Caveats: NONE



Tom



We've got the secured VTC set up for 19 FEB at 1200 (your time). Your
location will be the Fort Carson OSJA of?ce. Directions are below.

POC at Carson is?. Let me know if you have any questions.


Thanks,

Josh





From: USARMY 4 ID (US)

Sent: Wednesday, February 13, 2013 1:43 PM

To: Tooman, Joshua CPT USARMY (US)

Subject: RE: Secured VTC request (UNCLASSIFIED)



Classi?cation: UNCLASSIFIED

Caveats: NONE



>Sn-



The address is? but the building number isR. I'm
not sure it will come up on GPS, so here are directions.



He can enter through Gate 1 (Nelson off of HWY 115).
Take a right after he comes through the gate.

Take the second left (Carson Middle School will be on the right after
he

Page 1253 of 2169

turns)

Take a right at the 4 way stop.

Turn left into the ?rst parking lot, will be on his left.

Come through the main entrance in the er of the building and I
will meet him there.

Legal Administrator

Of?ce of the Staff Judge Advocate
4th Infantry Division Fort Carson



"Steadfast and Loyal"







From: Tooman, Joshua CPT USARMY (US)
Sent: Wednesday, February 13, 2013 11:38 AM





To: USARMY 4 ID CIV (US)
Cc:

Coombs; USARMY (US)

Subject: RE: Secured request (UNCLASSIFIED)



Classi?cation: UNCLASSIFIED

Caveats: NONE



Chief-, thanks for your help. Where is your of?ce located so
I can pass it on to the witness?



do you need any more information ?om me?





CPT Tooman





From: USARMY 4 ID (US)

Sent: Wednesday, February 13, 2013 1:03 PM

To: Tooman, Joshua CPT USARMY CIV (US)








9

Cc: David
Coombs;
Subject: RE: Secured


Classi?cation: UNCLASSIFIED
Caveats: NONE



>Sn-



USARMY (US)
request (UNCLASSIFIED)

He can use ours, we have a Tandberg in a secure location in our of?ce
if that works.


?at do you need from our end Page 1254 of 2169

02577



v/r,





Legal Administrator

Of?ce of the Staff Judge Advocate
4th Infantry Division Fort Carson




"Steadfast and Loyal"




From: Tooman, Joshua CPT USARMY (US)
Sent: Wednesday, February 13, 2013 10:16 AM

To: RUSARMY RUSARMY 4 ID
(US)

Cc: David Coombs

Subject: Secured VTC request (UNCLASSIFIED)



Classi?cation: UNCLASSIFIED

Caveats: NONE



ChiefF and Chie-



I am working on a court-martial with a number of witnesses who need to
discuss classi?ed information and& has indicated you

might be able to help me set up a re VTC with one such witness. I
am located at Fort Belvoir and understand there is a VTC at USALSA

that I could use. Also present would be MAJ Tom Hurley, my co-counsel
and Mr. Cass Hall, a defense security expert. The witness, Mr. Thomas
Hoskins, currently works at NORAD, but does not have access to a

secure VTC for the purposes of my interview with him. My hope is that Mr. Hoskins can use a VTC at Fort
Carson.



Mr. Hoskins is only available on the 18th and 19th. Understanding

that the 18th is a Federal holiday that would complicate setting this

up, we are looking at the 19th. Would it be possible to set something

up at 1200

Mountain/1400 Eastern on the 19th?



Thanks, in advance for your assistance, and please let me know if you

need any more information from me.







Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive

Fort Belvoir, VA 22060



Page 1255 of 2169

02578

02579





Classi?cation: UNCLASSIFIED
Caveats: NONE







Classi?cation: UNCLASSIFIED
Caveats: NONE







Classi?cation: UNCLASSIFIED
Caveats: NONE







Classi?cation: UNCLASSIFIED
Caveats: NONE







Classi?cation: UNCLASSIFIED
Caveats: NONE





Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1256 of 2169

From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW

Subject: RE: Contact Number for Mr. Prather (UNCLASSIFIED)
Date: VVednesday,February 13,2013 1:33:06 PM

02580



Classi?cation: UNCLASSIFIED
Caveats: NONE

I got in touch with him. Thanks, sir.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, February 13, 2013 12:46 PM

To: Tooman, Joshua CPT USARMY (US)

Subject: Re: Contact Number for Mr. Prather (UNCLASSIFIED)

Josh. I am out of the of?ce right now and will be back in an hour or so.

From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, February 13, 2013 04:26 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Subject: Contact Number for Mr. Prather (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE

Sir

Do you have a number other than_ for Mr. Prather?
Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel

9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1257 of 2169

02581

Page 1258 of 2169

From: Fein, Ashden MAJ USARMY MDW (US)

To: PT ARMY

Subject: Re: Contact Number for Mr. Prather (UNCLASSIFIED)
Date: Wednesday, February 13, 2013 12:45:55 PM

02582



Josh. I am out of the of?ce right now and will be back in an hour or so.

From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, February 13, 2013 04:26 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Subject: Contact Number for Mr. Prather (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE

Sir

Do you have a number other than_ for Mr. Prather?
Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Page 1259 of 2169

From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW

Subject: Contact Number for Mr. Prather (UNCLASSIFIED)
Date: Wednesday, February 13, 2013 11:26:56 AM

02583



Classi?cation: UNCLASSIFIED

Caveats: NONE

Sir

Do you have a number other than_ for Mr. Prather?
Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel

9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Page 1260 of 2169

02584



From: David Coombs

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


Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Mitroka, Katherine CPT USARMY

USARMY (US)

Subject: RE: Stip of Expected Testimony (UNCLASSIFIED)

Date: Wednesday, February 13, 2013 10:47:33 AM

Attachments: Sti of Ex ected Testimon -Mr

Angel,

Thank you for getting back to me on this in a timely manner. I accepted all
of the changes except for the "limited purposes of the motion" language. I
eliminated this language because the stip of expected testimony is not for
the purposes of the motion. It is my understand that COL Lind has already
determined that Mr. - would be relevant. However, due to his
concerns about being associated with the case, she wanted us to see if we
could enter into a stip of expected testimony. If I am wrong about this,
you obviously can still object to the relevance of Mr. - In other
words, entering into a stip of expected testimony does not admit to the
relevance or the admissibility of the information contained in the stip.

Let me know if you have any issues with this COA.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Sent: Wednesday, February 13, 2013 9:28 AM

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

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Mitroka, Katherine CPT USARMY
USARMY (US)

Subject: RE: Stip 0f Expected Testimony (UNCLASSIFIED)

Page 1261 of2169

02585

Classi?cation: UNCLASSIFIED
Caveats: NONE

David,

I made a couple minor changes, which I think more accurately re?ect what
- would say. In addition, I added that the Stipulation was for

limited purpose of the defense motion. Please let me know if you have
any issues with the changes. Thank you!

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Fort McNair, DC



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Friday, February 08, 2013 3:38 PM

To: David Coombs; Overgaard, Angel CPT USARMY Hurley, Thomas MAJ

USARMY Tooman, Joshua CPT USARMY (US)

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

USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony

David,

Angel is traveling right now. We received the information and she will get
back to you. Thank you.

v/r

Ashden



From: David Coombs [m il rm i

Sent: Friday, February 08, 2013 3:02 PM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY USARMY (US)

Subject: Stip of Expected Testimony

Angel,

I have attached a stipulation of expected testimony based upon our
conversation wit and the latest version of his declaration.
AlthoughF. con?rmed the facts regarding- and CPT
Tooman's second RFI during our conversation, I have attached the relevant

email as additional support for your bene?t. Let me know if you have any
questions.





Best,

Page 1262 of 2169

02586

David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1263 of 2169

02587

From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW

Subject: RE: (UNCLASSIFIED)

Date: Wednesday, February 13, 2013 8:33:01 AM



Classi?cation: UNCLASSIFIED
Caveats: NONE

Thanks, sir.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, February 12, 2013 1:49 PM

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

Cc: Morrow, JoDean (Joe) 111 CPT USARMY USAMDW
Overgaard, Angel CPT USARMY USARMY (US)

Subject: -

Defense,

is in town and available to be interviewed. The FBI informed us
that he was not available last week to be interviewed but is available this
week. (FBI) is CCed on this email and can assist with
coordinating interview. I know they are both available on
Thursday. is in town for training and is scheduled to return to
South Africa at the end of the week.






v/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1264 of 2169

02588






From: Fein, Ashden MAJ USARMY MDW (US)
To: PT ARMY "David gagmbs"; rl Th MA ARMY
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY
USARMY (US)
Bcc:
Mitroka, Katherine CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Whyte, Hunter CPT USARMY (US)
Subject:
Date: Tuesday, February 12, 2013 1:48:00 PM
Defense,

- is in town and available to be interviewed. The FBI informed us that he was not available last week to be

interviewed but is available this week.

(FBI) is CCed on this email and can assist with coordinating

interview. I know they are both available on Thursday. - is in town for training and is
scheduled to return to South Africa at the end of the week.

v/r
MAJ Fein

Page 1265 of 2169

02589

From: Fein, Ashden MAJ USARMY MDW (US)

To: "David (bombs'; rl Th MA ARMY

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







Bcc:
1&1; USARMY
Mitroka, Katherine CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Whyte, Hunter CPT USARMY (US)
Subject: RE: PFC BM
Date: Tuesday, February 12, 2013 8:02:00 AM
David,

Good morning. The command will be able to support the below request.

v/r

Ashden



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Tuesday, February 05, 2013 5:16 PM

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

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

Subject: PFC BM

Ashden,

Please have PFC BM brought to the Fort Meade TDS Of?ce at 0930 on 25
February 2012. I anticipate the need to meet with him until 1600. Thank
you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1266 of 2169

From: Tooman, Joshua CPT USARMY (US)
To: An IM PT ARMY

Cc: Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: Email Address (UNCLASSIFIED)
Date: Monday, February 11, 2013 5:43:48 PM

02590



Classi?cation: UNCLASSIFIED
Caveats: NONE

Thanks, Angel.



From: Overgaard, Angel CPT USARMY (US)
Sent: Monday, February 11, 2013 5:31 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW (US)
Subject: Email Address (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Josh,

Thomas Hoskins asked me to forward you this email address as he is currently

ocows:

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Fort McNair, DC

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1267 of 2169

02591

Page 1268 of 2169

02592



From: Fein, Ashden MAJ USARMY MDW (US)

To: r Th MA ARMY

Bcc: Morrow, JoDean (Joe) CPT USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Date: Monday, February 11, 2013 7:42:00 AM

MAJ Hurley,

Thank you for the reply. If you are meeting everyone at the visitor's center then LtCol Nehring should be able to
meet you there as well.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)
Sent: Monday, February 11, 2013 7:27 AM
To: Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

MAJ Fein

We have no witness issues right now. We should be able to speak with the CENTCOM witnesses while down there,
and I believe we will be able to cover the classi?ed interviews we have left with the security experts already
detailed to the defense team. Sorry for not conveying this

I received your note about LtCol (Retired) Nehring. We should be able to fit all of our questions in those
parameters. He's our ?rst scheduled meeting (0900 tomorrow). I will speak with him today in order to determine
the location. (He can't even go inside the Visitors Center? That's where he's scheduled to be now.) I imagine it
will be at some MacDill AFB park, weather permitting. Our hotel is too far away from CENTCOM HQ to have our
meeting there as scheduled and make it to the next appointment we have.

Call me on my cell if you need me whilst I am in Tampa.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Monday, February 11, 2013 2:59 AM

To: Hurley, Thomas MAJ USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)

MAJ Hurley,

I never heard back from you last week. I just wanted to make sure you did not have any issues with CENTCOM
witnesses or any other witnesses. I just responded to the everyone about LtCol(Ret) Nehring.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, February 06, 2013 4:00 PM
To: Hurley, Thomas MAJ USARMY (US)

Page 1269 of 2169

02593

Subject: RE: LOA (UNCLASSIFIED)
MAJ Hurley-

I called and left a message on your of?ce phone. If you have time today or tomorrow afternoon, could we chat
again? It?s a follow-up ?om Monday and I wanted to make sure you guys were good with a few other issues.

Thanks!



From: Hurley; Thomas MAJ USARMY (US)
Sent: Wednesday, February 06; 2013 3:25 PM
To: Fein; Ashden MAJ USARMY MDW








USARMY USAMDW (US)

Cc: USARMY USARMY USAMDW
CIV USAF (US)
ubject: RE: LOA (UNCLASSIFIED)

(6
MAJ Fein

Thanks for your consideration of this matter. I hate to be responsible for additional personnel being brought in to
perform additional duties; but it is probably best for the parties to avoid unnecessary confrontation about travel.

MAJ Hurley



From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Wednesday; February 06; 2013 8:20 PM

To: Hurley; Thomas MAJ USARMY
Cc: USARMY








USARMY USAMDW (US)

USARMY USAMDW

CIV CIV USAF (US)

bject: RE: LOA (UNCLASSIFIED)

MAJ Hurley;
6
This afternoon I discussed the potential effects of this with and realizing that one of our paralegals
would be in your approving chain; I asked% - to reevaluate the best method to process
your travel requests; which does not inclu member of the ec in this case approving/disapproving your

travel or having any other role in your travel.

They decided that it would be more ef?cient and appropriate for the main of?ce to process your travel vice the
prosecution. Please submit any questions or comments about travel; including issues with DTS to and

(CCed) as your reviewing of?cials. - anda USAF (CCed) are your

approving of?cials.
Thank you!

v/r
MAJ Fein



From: Hurley; Thomas MAJ USARMY (US)

Sent: Wednesday; February 06; 2013 3: 12 PM

To: USARMY USAMDW (US)

Cc: Fein; Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)



P?ge 1270 of 2169

02594

Thanks!

v/r
MAJ Hurley



From: USARMY USAMDW (US)

Sent: Wednesday, February 06, 2013 5:36 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

As per the e-mail traf?c below, a decision has been made I regards to your
request for support by_ MDW will take care of the costs
associated with your TDY in support of this case. FYSA, I will be the
approving of?cial for all travel when using the US v. Manning LOA. Thus,
if you have any questions please do not reach out to your command as they do
not control the reviewing or approval processes with this LOA. The LOA is
labeled 13 US and it should be located under your CrossOrg
accounting labels. The LOA is loaded already in your pro?le so you can
schedule your travel at your convenience. Thank you.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and





Page 1271 of2169

02595

From:

Sent: Wednesday, February 06, 2013 11:38 AM

To: USARMY USAMDW (US)
Cc

(US)

Subject: FW: LOA (UNCLASSIFIED)

NILE

Please inform MAJ Hurley that_ spoke directly with

about the ambiguity in the regulation, rather than waiting for MAJ Hurley to
run this issue up through TDS channels. suggested that we will
{?nd MAJ Hurley's travel under the circumstances of this case.

They agreed that a gaining organization would obviously not be responsible

for travel costs incurred by a defense counsel who had been previously

detailed, but that it was a policy decision on whether it would be better

for USATDS to continue to be responsible after a PCS from USATDS or whether
the burden should automatically shift to the convening authority as it would

in the case where the IMC was not assigned to TDS when appointed.

Since the entire cost assessed for these court-martial proceedings will

ultimately be analyzed and executed by the Army Budget Of?ce IAW HQDA EXORD
206-11, it makes more practical sense to consolidate the costs at this

Headquarters rather than require USATDS to submit a UFR for any

extraordinary costs a second non-TDS IMC detailed for this complex

case) or require another IMC request to be processed through this GCMCA to
determine "reasonable availability" from the perspective of the gaining

organization.

Accordingly, please add MAJ Hurley to the line of accounting as quickly as
possible to ensure he can complete any related travel without delay. As CPT
Tooman remains assigned to TDS, his LOA remains at TDS. In addition, please
make any necessary coordination with the TDS legal administrator as well.

Please contact me if you have any questions.

v/r







JFHQ-NCR and US. Army Military District of Washington

Fort Lesley J. McNair, DC 20319-5058



From: USARMY USAMDW (US)
Sent: Tuesday, February 05, 2013 4:05 PM

To:

Cc: (US)

Subject: FW: LOA (UNCLASSIFIED)

Page 1272 of 2169

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

Below is the issue we discussed in regards to funding of TDS counsel in the

case of US V. Manning. As far as the information you requested, MAJ Hurley
was requested as an IMC in 25 April 2012. When the IMC request was approved
by the CA he was part of TDS. MAJ Hurley was assigned to the Military
Commissions on 2 July 2012. As far as CPT Tooman is concerned he was
requested as an IMC but has never left TDS and is currently assigned to the

TDS of?ce at Ft. Belvoir.

v/r,






JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 2:42 PM

To: USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

I would direct your attention to AR 27-10, paragraph Therein, it
is indicated that "convening authorities will continue to
appearance of individual military counsel not currently assigned to

I don't mean to brag, and I don't mean to boast, but I qualify under both

prongs of that regulatory language. in June - left TDS in July.) I
would go farther and say that the CA should pay for the travel of both CPT

Page 1273 of 2169

02596

02597

Tooman and myself because we are both post-referral IMC requests that were
granted by the CA. But CPT Tooman and TDS can work that out internally or
with the CA or his designated rep (I'm guessing that's you).

Anyway. My Please tell me when it's loaded.
Thanks.

MAJ Hurley



From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 6:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

MDW does not fund TDS attorneys' travel for this case or any other. The
only funding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any funding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
?irther questions please feel ?ee to contact me at your convenience.

v/r,






JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and

Page 1274 of 2169


From: Hurley, Thomas MAJ USARMY (US)
Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief

Would you add the Manning LOA to my cross org
Thanks.

Tom Hurley

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1275 of 2169

02598

02599



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

Date: Monday, February 11, 2013 7:26:46 AM
MAJ Fein

We have no witness issues right now. We should be able to speak with the CENTCOM witnesses while down there,
and I believe we will be able to cover the classi?ed interviews we have left with the security experts already
detailed to the defense team. Sorry for not conveying this

I received your note about LtCol (Retired) Nehring. We should be able to fit all of our questions in those
parameters. He's our ?rst scheduled meeting (0900 tomorrow). I will speak with him today in order to determine
the location. (He can't even go inside the Visitors Center? That's where he's scheduled to be now.) I imagine it
will be at some MacDill AFB park, weather permitting. Our hotel is too far away from CENTCOM HQ to have our
meeting there as scheduled and make it to the next appointment we have.

Call me on my cell if you need me whilst I am in Tampa.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Monday, February 11, 2013 2:59 AM

To: Hurley, Thomas MAJ USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)

MAJ Hurley,

I never heard back from you last week. I just wanted to make sure you did not have any issues with CENTCOM
witnesses or any other witnesses. I just responded to the everyone about LtCol(Ret) Nehring.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, February 06, 2013 4:00 PM
To: Hurley, Thomas MAJ USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)

MAJ Hurley-

I called and left a message on your of?ce phone. If you have time today or tomorrow afternoon, could we chat
again? It?s a follow-up from Monday and I wanted to make sure you guys were good with a few other issues.

Thanks!

From: Hurley, Thomas MAJ USARMY (US)

Sent: Wednesday, February 06, 2013 3:25 PM
To: Fein, Ashden MAJ USARMY MDW USARMY USAMDW (US)

Cc: USARMY USARMY USAMDW
FCIV CIV USAF (US)
(6

Page 1276 of 2169

02600

Subject: RE: LOA (UNCLASSIFIED)
MAJ Fein

Thanks for your consideration of this matter. I hate to be responsible for additional personnel being brought in to
perform additional duties, but it is probably best for the parties to avoid unnecessary confrontation about travel.

MAJ Hurley



From: Fein; Ashden MAJ USARMY MDW (US)

Sent: Wednesday, February 06; 2013 8:20 PM

To: Hurley; Thomas MAJ USARMY

Cc: USARMY

CIV
ubject: RE: LOA (UNCLASSIFIED)

(6

MAJ Hurley;








USARMY USAMDW (US)

USARMY USAMDW

USAF (US)




This afternoon I discussed the potential effects of this with
would be in your approving chain; I asked%
your travel requests; which does not inclu member of the

travel or having any other role in your travel.

and realizing that one of our paralegals
to reevaluate the best method to process
ec in this case approving/disapproving your

They decided that it would be more ef?cient and appropriate for the main of?ce to process your travel vice the
prosecution. Please submit any questions or comments about travel; including issues with DTS to - and

(CCed) as your reviewing of?cials. - anda - USAF (CCed) are your

approving of?cials.
Thank you!

v/r
MAJ Fein



From: Hurley; Thomas MAJ USARMY (US)

Sent: Wednesday; February 06; 2013 3: 12 PM

To: USARMY USAMDW (US)

Cc: Fein; Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)



(Blanks!


v/r
MAJ Hurley

From: USARMY USAMDW (US)

Sent: Wednesday; February 06; 2013 5:36 PM

To: Hurley; Thomas MAJ USARMY (US)

Cc: Fein; Ashden MAJ USARMY MDW USARMY (US)
Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1277 of 2169

02601

Sir,

As per the e-mail traf?c below, a decision has been made I regards to your
request for support by_ MDW will take care of the costs
associated with your TDY in support of this case. FYSA, I will be the
approving of?cial for all travel when using the US V. Manning LOA. Thus,
if you have any questions please do not reach out to your command as they do
not control the reviewing or approval processes with this LOA. The LOA is
labeled 13 US MA and it should be located under your CrossOrg
accounting labels. The LOA is loaded already in your pro?le so you can
schedule your travel at your convenience. Thank you.

v/r,



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 11:38 AM

To: USARMY USAMDW (US)
Cc: USARMY 5 USARMY USAMDW

(US)
Subject: FW: LOA (UNCLASSIFIED)



Please inform MAJ Hurley that_ spoke directly with%

about the ambiguity in the regulation, rather than waiting for MA url to
run this issue up through TDS channels. suggested that we will

?nd MAJ Hurley's travel under the circumstances of this case.

They agreed that a gaining organization would obviously not be responsible

Page 1278 of 2169

02602

for travel costs incurred by a defense counsel who had been previously

detailed, but that it was a policy decision on whether it would be better

for USATDS to continue to be responsible after a PCS from USATDS or whether
the burden should automatically shift to the convening authority as it would

in the case where the IMC was not assigned to TDS when appointed.

Since the entire cost assessed for these court-martial proceedings will

ultimately be analyzed and executed by the Army Budget Of?ce IAW HQDA EXORD
206-11, it makes more practical sense to consolidate the costs at this

Headquarters rather than require USATDS to submit a UFR for any

extraordinary costs a second non-TDS IMC detailed for this complex

case) or require another IMC request to be processed through this GCMCA to
determine "reasonable availability" from the perspective of the gaining

organization.

Accordingly, please add MAJ Hurley to the line of accounting as quickly as
possible to ensure he can complete any related travel without delay. As CPT
Tooman remains assigned to TDS, his LOA remains at TDS. In addition, please
make any necessary coordination with the TDS legal administrator as well.

Please contact me if you have any questions.

v/r



puty Staff Judge Advocate
JFHQ-NCR and US. Army Military District of Washington




Fort Lesley J. McNair, DC 20319-5058








From: USARMY USAMDW (US)
Sent: Tuesday, February 05, 2013 4:05 PM

To: USARMY USAMDW (US)

USARMY USAMDW (US)
Subject: FW: LOA (UN SSIFIED)
Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

Below is the issue we discussed in regards to funding of TDS counsel in the

case of US v. Manning. As far as the information you requested, MAJ Hurley
was requested as an IMC in 25 April 2012. When the IMC request was approved
by the CA he was part of TDS. MAJ Hurley was assigned to the Military
Commissions on 2 July 2012. As far as CPT Tooman is concerned he was
requested as an IMC but has never left TDS and is currently assigned to the

TDS of?ce at Ft. Belvoir.

v/r,

Page 1279 of 2169

02603



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization from the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 2:42 PM

To: USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

55

I would direct your attention to AR 27-10, paragraph Therein, it
is indicated that "convening authorities will continue to
appearance of individual military counsel not currently assigned to

I don't mean to brag, and I don't mean to boast, but I qualify under both
prongs of that regulatory language. in June - left TDS in July.) I
would go farther and say that the CA should pay for the travel of both CPT
Tooman and myself because we are both post-referral IMC requests that were
granted by the CA. But CPT Tooman and TDS can work that out internally or
with the CA or his designated rep (I'm guessing that's you).

Anyway. My SSN i_ Please tell me when it's loaded.

Thanks.
MAJ Hurley

From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 6:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Page 1280 of 2169

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

MDW does not fund TDS attomeys' travel for this case or any other. The
only funding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any funding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
?irther questions please feel ?ee to contact me at your convenience.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and





From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief

Would you add the Manning LOA to my cross org

Page 1281 of2169

02604

02605

Thanks.

Tom Hurley

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1282 of 2169

02606



From: Fein, Ashden MAJ USARMY MDW (US)

To: rl Th MA ARMY

Bcc: Morrow, JoDean (Joe) CPT USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Date: Sunday, February 10, 2013 9:59:00 PM

MAJ Hurley,

I never heard back from you last week. I just wanted to make sure you did not have any issues with CENTCOM
witnesses or any other witnesses. I just responded to the everyone about LtCol(Ret) Nehring.

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, February 06, 2013 4:00 PM
To: Hurley, Thomas MAJ USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)

MAJ Hurley-

I called and left a message on your of?ce phone. If you have time today or tomorrow afternoon, could we chat
again? It?s a follow-up from Monday and I wanted to make sure you guys were good with a few other issues.

Thanks!


From: Hurley, Thomas MAJ USARMY (US)
Sent: Wednesday, February 06, 2013 3:25 PM

To: Fein, Ashden MAJ USARMY MDW
Cc: USARMY








USARMY USAMDW (US)

USARMY USAMDW

CIV CIV USAF (US)
bject: RE: LOA (UNCLASSIFIED)



MAJ Fein

6

Thanks for your consideration of this matter. I hate to be responsible for additional personnel being brought in to
perform additional duties, but it is probably best for the parties to avoid unnecessary confrontation about travel.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, February 06, 2013 8:20 PM

To: Hurley, Thomas MAJ USARMY
Cc: USARMY








USARMY USAMDW (US)

USARMY USAMDW

CIV CIV USAF (US)
bject: RE: LOA (UNCLASSIFIED)



MAJ Hurley,

6




and realizing that one of our paralegals
to reevaluate the best method to process
ec in this case approving/disapproving your

This afternoon I discussed the potential effects of this with
would be in your approving chain, I asked(%
your travel requests, which does not inclu member of the

Page 1283 of 2169

02607

travel or having any other role in your travel.

They decided that it would be more ef?cient and appropriate for the main of?ce to process your travel vice the
prosecution. Please submit any questions or comments about travel, including issues with DTS to - and

(CCed) as your reviewing of?cials. - anda -, USAF (CCed) are your

approving of?cials.
Thank you!

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Wednesday, February 06, 2013 3: 12 PM

To: USARMY USAMDW (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)



(Blanks!


v/r
MAJ Hurley

From: USARMY USAMDW (US)

Sent: Wednesday, February 06, 2013 5:36 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

As per the e-mail traf?c below, a decision has been made I regards to your
request for support by_ MDW will take care of the costs
associated with your TDY in support of this case. FYSA, I will be the
approving of?cial for all travel when using the US v. Manning LOA. Thus,
if you have any questions please do not reach out to your command as they do
not control the reviewing or approval processes with this LOA. The LOA is
labeled 13 US and it should be located under your CrossOrg
accounting labels. The LOA is loaded already in your pro?le so you can
schedule your travel at your convenience. Thank you.

v/r,

5 A
gal Administrator

JFHQ-NCR, MDW

Page 1284 of 2169

02608



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attorney-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 11:38 AM

To: USARMY USAMDW (US)

Cc: USARMY 5 USARMY USAMDW
(US

Subject: FW: LOA (UNCLASSIFIED)



Please inform MAJ Hurley that_ spoke directly with

about the ambiguity in the regulation, rather than waiting for MAJ Hurley to
run this issue up through TDS channels. suggested that we will
fund MAJ Hurley's travel under the circumstances of this case.

They agreed that a gaining organization would obviously not be responsible

for travel costs incurred by a defense counsel who had been previously

detailed, but that it was a policy decision on whether it would be better

for USATDS to continue to be responsible after a PCS ?om USATDS or whether
the burden should automatically shift to the convening authority as it would

in the case where the IMC was not assigned to TDS when appointed.

Since the entire cost assessed for these court-martial proceedings will

ultimately be analyzed and executed by the Army Budget Of?ce IAW HQDA EXORD
206-11, it makes more practical sense to consolidate the costs at this

Headquarters rather than require USATDS to submit a UFR for any

extraordinary costs a second non-TDS IMC detailed for this complex

case) or require another IMC request to be processed through this GCMCA to
determine "reasonable availability" ?om the perspective of the gaining

organization.

Accordingly, please add MAJ Hurley to the line of accounting as quickly as
possible to ensure he can complete any related travel without delay. As CPT
Tooman remains assigned to TDS, his LOA remains at TDS. In addition, please

make any necessary coordination with the TDS legal administrator as well.

Please contact me if you have any questions.

Page 1285 of 2169

v/r



puty Staff Judge Advocate
JFHQ-NCR and US. Army Military District of Washington






Fort Lesley J. McNair, DC 20319-5058



From: USARMY USAMDW (US)
Sent: Tuesday, February 05, 2013 4:05 PM

To: USARMY USAMDW (US)

USARMY USAMDW (US)
Subject: FW: LOA (UN SSIFIED)
Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

Below is the issue we discussed in regards to {?nding of TDS counsel in the

case of US V. Manning. As far as the information you requested, MAJ Hurley
was requested as an IMC in 25 April 2012. When the IMC request was approved
by the CA he was part of TDS. MAJ Hurley was assigned to the Military
Commissions on 2 July 2012. As far as CPT Tooman is concerned he was
requested as an IMC but has never left TDS and is currently assigned to the

TDS of?ce at Ft. Belvoir.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW
mil@mail mil




The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization from the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

Page 1286 of 2169

02609

02610

action in reliance on this information is prohibited. If you received this
email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 2:42 PM

To: USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

55

I would direct your attention to AR 27-10, paragraph Therein, it
is indicated that "convening authorities will continue to
appearance of individual military counsel not currently assigned to

I don't mean to brag, and I don't mean to boast, but I qualify under both
prongs of that regulatory language. in June - left TDS in July.) I
would go farther and say that the CA should pay for the travel of both CPT
Tooman and myself because we are both post-referral IMC requests that were
granted by the CA. But CPT Tooman and TDS can work that out internally or
with the CA or his designated rep (I'm guessing that's you).

Anyway. My SSN is_ Please tell me when it's loaded.
Thanks.
MAJ Hurley

From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 6:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

MDW does not fund TDS attorneys' travel for this case or any other. The
only funding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any funding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
further questions please feel free to contact me at your convenience.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW

Page 1287 of 2169

02611



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attorney-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief

Would you add the Manning LOA to my cross org

Thanks.

Tom Hurley

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1288 of 2169

02612

Page 1289 of 2169

02613

From: Fein, Ashden MAJ USARMY MDW (US)

To: r Th MA ARMY

Cc: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall. Cassius CIV (US)







Bcc:
1&1; USARMY
Mitroka, Katherine CPT USARMY (US)
Subject: RE: Martin Nehring (UNCLASSIFIED)
Date: Sunday, February 10, 2013 9:36:00 PM
MAJ Hurley,

Good evening. We ?nally received an answer late Friday on what is required for LtCol(Ret) Nehring and his
clearance. Because neither the government nor defense will be sharing any classi?ed information that he already
has not been privy to, all he needs to do is sign a new NDA and we keep it on ?le. We are coordinating with
CENTCOM to see if they can have him execute a new NDA before your meeting.

1. When is your meeting with him scheduled this week?
2. He will not be authorized to enter CENTCOM HQ, therefore where will you have your meeting with him?
Thanks!

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Friday, February 08, 2013 9:06 AM

To: Fein, Ashden MAJ USARMY MDW 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 Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

All

I was speaking with Cass about this topic this morning. Couldn't Mr. Nehring just speak about what he knows if he
is told he can speak with us?

Also, aren't we in the same space that we are with Mr. Lamo? Just asking him about his knowledge and actions
while neither con?rming nor denying what he is telling us?

Finally, doesn't the fact of his retirement (as opposed to ETS'ing) matter? He's still subject to the code (sort of).
trying to imagine workarounds.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 9:10 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe)

Page 1290 of 2169

02614

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Hall, Cassius CIV (US)
Subject: RE: Martin Nehring (UNCLASSIFIED)

Thanks. I hope to have this resolved by then. Angel is actually down there
right now and intends to chat with him today or tomorrow, but unclas so we
can ?gure out what needs to occur. MTF.



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 4:07 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Roger, sir. Please give us a heads up when we are cleared to speak
classi?ed with him. MAJ and Cass will be in Tampa conducting interviews
next week and are slated to speak to Mr. Nehring on Tuesday morning.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 3:53 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Josh,

He informed us of that this week as well. At this point no, but we are
working to ?gure out what needs to occur for both the prosecution and
defense to discuss classi?ed information with him.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 3:41 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Page 1291 of2169

02615

Subject: Martin Nehring (UNCLASSIFIED)
Classi?cation: UNCLASSIFIED

Caveats: NONE

Sir

Are we cleared to discuss classi?ed info with the above-captioned witness?
He has indicated that he no longer has an active security clearance.

Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1292 of 2169

02616



From: David Coombs

To: in A MA ARMY MDW QVergaard, Angel QPT LJSARMY Hurley, Thomas MAJ LJSARMY
PT ARMY

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

Subject: RE: Stip of Expected Testimony

Date: Friday, February 08, 2013 3:58:05 PM

Ashden,

Thank you.

Best,

David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Friday, February 08, 2013 3:38 PM

To: David Coombs; Overgaard, Angel CPT USARMY Hurley, Thomas MAJ

USARMY Tooman, Joshua CPT USARMY (US)

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

USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Stip of Expected Testimony

David,

Angel is traveling right now. We received the information and she will get
back to you. Thank you.

v/r

Ashden



From: David Coombs com]

Sent: Friday, February 08, 2013 3:02 PM
To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY (US)

Page 1293 of 2169

02617

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)

CPT USARMY USARMY (US)
Subject: Stip of Expected Testimony

Angel,

I have attached a stipulation of expected testimony based upon our
conversation with and the late st version of his declaration.




Althoughg con?rmed the facts regarding and CPT
Tooman's 0nd I during our conversation, Ihave ac the relevant
email as additional support for your bene?t. Let me know if you have any
questions.

Best,

David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Page 1294 of 2169

02618

From: Fein, Ashden MAJ USARMY MDW (US)

To: "David gagmbs"; Qvergaard, Angel QPT LJSARMY Hurley, Thomas MAJ LJSARMY Tooman, aJoshua
,1 (PT LJSARMY (L13)

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



(Alec) CPT USARMY USARMY (US)

Bcc:
Mitroka Katherine

CPT USARMY (US)







Subject: RE: Stip of Expected Testimony
Date: Friday, February 08, 2013 3:38:00 PM
David,

Angel is traveling right now. We received the information and she will get back to you. Thank you.

v/r

Ashden



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Friday, February 08, 2013 3:02 PM

To: Overgaard, Angel CPT USARMY Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: Stip of Expected Testimony

Angel,

I have attached a stipulation of expected testimony based upon our
conversation with and the latest version of his declaration.
AlthoughF. con?rmed the facts regarding and CPT
Tooman's second RFI during our conversation, I have ac the relevant

email as additional support for your bene?t. Let me know if you have any
questions.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1295 of 2169

02619

Page 1296 of 2169

02620

From: David Coombs

To: Qvergaard, Angel LJSARMY Hurley, Thomas MAJ LJSARMY Tooman, Joshua ,1 LJSARMY
.05).

Cc: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: Stip of Expected Testimony
Date: Friday, February 08, 2013 3:02:04 PM

Attachments: FW Update
Stip of Expected Testimony-ML? ocx



Angel,

I have attached a stipulation of expected testimony based upon our
conversation with and the late st version of his declaration.





Althoughg con?rmed the facts regardingW and CPT
Tooman's 0nd I during our conversation, Ihave a the relevant
email as additional support for your bene?t. Let me know if you have any
questions.

Best,

David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential 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 unlaw?il and is prohibited.

Page 1297 of 2169

02621

From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ USARMY Tooman, lJoshua QPT USARMY (US)

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





Bcc:
1&1; USARMY
Mitroka, Katherine CPT USARMY (US)
Subject: RE: Martin Nehring (UNCLASSIFIED)
Date: Friday, February 08, 2013 9:38:00 AM
MAJ Hurley,

We agree that you can discuss with Mr. Nehring's his involvement in this case, so long as you do not discuss the
contents of the classi?ed SIGACTs. Although his expected testimony is based on a portion of the SIGACTs, he
should be able to discuss process and generalities about what he did to review the SIGACTs. Without proper
authorization, we cannot share classi?ed information with him, therefore neither party can discuss the actual
SIGACTs.

We are working to ?gure out who would grant him access to the information now that he is ?illy retired and not
working at CENTCOM any longer. Being retired should speed up the process. Also, once he is granted access, we
also have to coordinate to allow him into a government facility to actually view and discuss the information.

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Friday, February 08, 2013 9:06 AM

To: Fein, Ashden MAJ USARMY MDW 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 Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

All

I was speaking with Cass about this topic this morning. Couldn't Mr. Nehring just speak about what he knows if he
is told he can speak with us?

Also, aren't we in the same space that we are with Mr. Lamo? Just asking him about his knowledge and actions
while neither con?rming nor denying what he is telling us?

Finally, doesn't the fact of his retirement (as opposed to ETS'ing) matter? He's still subject to the code (sort of).
trying to imagine workarounds.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Thursday, February 07, 2013 9:10 PM
To: Tooman, Joshua CPT USARMY (US)

Page 1298 of 2169

02622

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Thanks. I hope to have this resolved by then. Angel is actually down there
right now and intends to chat with him today or tomorrow, but unclas so we
can ?gure out what needs to occur. MTF.



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 4:07 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Roger, sir. Please give us a heads up when we are cleared to speak
classi?ed with him. MAJ and Cass will be in Tampa conducting interviews
next week and are slated to speak to Mr. Nehring on Tuesday morning.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 3:53 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Josh,

He informed us of that this week as well. At this point no, but we are
working to ?gure out what needs to occur for both the prosecution and
defense to discuss classi?ed information with him.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 3:41 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

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

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

Page 1299 of 2169

CPT USARMY Hall, Cassius CIV (US)
Subject: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE
Sir

Are we cleared to discuss classi?ed info with the above-captioned witness?
He has indicated that he no longer has an active security clearance.

Thanks,
Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1300 of 2169

02623

02624

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

Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Hall, Cassius CIV (US)



Subject: RE: Martin Nehring (UNCLASSIFIED)
Date: Friday, February 08, 2013 9:06:09 AM
All

I was speaking with Cass about this topic this morning. Couldn't Mr. Nehring just speak about what he knows if he
is told he can speak with us?

Also, aren't we in the same space that we are with Mr. Lamo? Just asking him about his knowledge and actions
while neither con?rming nor denying what he is telling us?

Finally, doesn't the fact of his retirement (as opposed to ETS'ing) matter? He's still subject to the code (sort of).
trying to imagine workarounds.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 9: 10 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Thanks. I hope to have this resolved by then. Angel is actually down there
right now and intends to chat with him today or tomorrow, but unclas so we
can ?gure out what needs to occur. MTF.



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 4:07 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Roger, sir. Please give us a heads up when we are cleared to speak
classi?ed with him. MAJ and Cass will be in Tampa conducting interviews

next week and are slated to speak to Mr. Nehring on Tuesday morning.

Thanks,

Page 1301 of2169

02625

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 3:53 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Josh,

He informed us of that this week as well. At this point no, but we are
working to ?gure out what needs to occur for both the prosecution and
defense to discuss classi?ed information with him.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 3:41 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE
Sir

Are we cleared to discuss classi?ed info with the above-captioned witness?
He has indicated that he no longer has an active security clearance.

Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Page 1302 of 2169

02626

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1303 of 2169

02627

From: Fein, Ashden MAJ USARMY MDW (US)
To: PT ARMY
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall. Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Date: Thursday, February 07, 2013 4:10:00 PM





Thanks. I hope to have this resolved by then. Angel is actually down there
right now and intends to chat with him today or tomorrow, but unclas so we
can ?gure out what needs to occur. MTF.



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 4:07 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Roger, sir. Please give us a heads up when we are cleared to speak
classi?ed with him. MAJ and Cass will be in Tampa conducting interviews
next week and are slated to speak to Mr. Nehring on Tuesday morning.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 3:53 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Josh,
He informed us of that this week as well. At this point no, but we are
working to ?gure out what needs to occur for both the prosecution and

defense to discuss classi?ed information with him.

v/r
MAJ Fein


From: Tooman, Joshua CPT USARMY (US)
Sent: Thursday, February 07, 2013 3:41 PM

Page 1304 of 2169

02628

To: Fein; Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard; Angel CPT

USARMY Whyte; Hunter CPT USARMY von Elten; Alexander (Alec)
CPT USARMY Hall; Cassius CIV (US)

Subject: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE

Sir

Are we cleared to discuss classi?ed info with the above-captioned witness?
He has indicated that he no longer has an active security clearance.

Thanks;

Josh

Joshua J. Tooman

JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir; VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1305 of 2169

02629

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall. Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Date: Thursday, February 07, 2013 4:06:38 PM





Classi?cation: UNCLASSIFIED
Caveats: NONE

Roger, sir. Please give us a heads up when we are cleared to speak
classi?ed with him. MAJ and Cass will be in Tampa conducting interviews
next week and are slated to speak to Mr. Nehring on Tuesday morning.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 3:53 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: RE: Martin Nehring (UNCLASSIFIED)

Josh,

He informed us of that this week as well. At this point no, but we are
working to ?gure out what needs to occur for both the prosecution and
defense to discuss classi?ed information with him.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 3:41 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE
Sir

Are we cleared to discuss classi?ed info with the above-captioned witness?
He has indicated that he no longer has an active security clearance.

Page 1306 of 2169

02630

Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1307 of 2169

02631

From: Fein, Ashden MAJ USARMY MDW (US)

To: PT ARMY

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall, Cassius CIV (US)







Bcc:
USARMY
Mitroka, Katherine CPT USARMY (US)
Subject: RE: Martin Nehring (UNCLASSIFIED)
Date: Thursday, February 07, 2013 3:53:00 PM
Josh,

He informed us of that this week as well. At this point no, but we are
working to ?gure out what needs to occur for both the prosecution and
defense to discuss classi?ed information with him.

V/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 3:41 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY

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

USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV (US)

Subject: Martin Nehring (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE
Sir

Are we cleared to discuss classi?ed info with the above-captioned witness?
He has indicated that he no longer has an active security clearance.

Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Page 1308 of 2169

02632

Page 1309 of 2169

02633

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT



USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall. Cassius CIV (US)

Subject: Martin Nehring (UNCLASSIFIED)

Date: Thursday, February 07, 2013 3:40:47 PM

Classi?cation: UNCLASSIFIED
Caveats: NONE
Sir

Are we cleared to discuss classi?ed info with the above-captioned witness? He has indicated that he no longer has

an active security clearance.
Thanks,

Josh

Joshua J. Tooman

CPT, JA

Trial Defense Counsel
9990 Belvoir Drive
Fort Belvoir, VA 22060



Classi?cation: UNCLASSIFIED

Caveats: NONE

Page 1310 of2169

02634





From: Fein, Ashden MAJ USARMY MDW (US)

To: Th MA ARMY David (bombs; Tooman, Joshua ,1 (PT 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: Security Expert Request

Date: Thursday, February 07, 2013 3:31 :00 PM

Thank you!



From: Hurley, Thomas MAJ USARMY (US)

Sent: Thursday, February 07, 2013 3:24 PM

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

Subject: RE: Security Expert Request
MAJ Fein
Acknowledged. We will let you know tomorrow morning.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, February 06, 2013 10:14 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 (US)

Subject: Security Expert Request
Defense,

This week, I spoke with MAJ Hurley and CPT Tooman separately about requesting an additional security expert to
assist the defense with interviews between now and 22 February. If this is something you would like or need,
please submit a written request with detailed justi?cation as soon as possible. The prosecution will ?illy support
the request and expeditiously move it forward for action, but the justi?cation must be detailed and include why your
two experts are not adequate for this period. I am optimistic that the request will be ful?lled, so long as the request
is for a third expert to assist with getting through the next few weeks for your interviews.

Please let me know if you have any questions.

v/r

Ashden

Page 1311 of2169

02635



From: Hurley, Thomas MAJ USARMY (US)

To: Fein, Ashden MAJ USARMY MDW David (bombs; Tooman, lJoshua USARMY (LJS)

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: Security Expert Request

Date: Thursday, February 07, 2013 3:24:23 PM

MAJ Fein

Acknowledged. We will let you know tomorrow morning.

v/r
MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, February 06, 2013 10:14 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 (US)

Subject: Security Expert Request
Defense,

This week, I spoke with MAJ Hurley and CPT Tooman separately about requesting an additional security expert to
assist the defense with interviews between now and 22 February. If this is something you would like or need,
please submit a written request with detailed justi?cation as soon as possible. The prosecution will ?illy support
the request and expeditiously move it forward for action, but the justi?cation must be detailed and include why your
two experts are not adequate for this period. I am optimistic that the request will be ful?lled, so long as the request
is for a third expert to assist with getting through the next few weeks for your interviews.

Please let me know if you have any questions.

v/r

Ashden

Page 1312 of2169

02636

From: Hurley, Thomas MAJ USARMY (US)

To: USARMY USAMDW TQQman Joshua ,1ng Fein Ashden MAJ
USARMY MDW (us)

Cc: "David Coombs"; USARMY USAMDW (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Date: Thursday, February 07, 2013 3:20:11 PM



ChiefR

Text me at_ and tell me what time you will be at work tomorrow morning. I will bring the dongles by
for your viewing 0/ a that time.

Thanks.

MAJ Hurley



From: USARMY USAMDW (US)

Sent: Thursday, February 07, 2013 6: 17 PM

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

Cc: 'David Coombs'; USARMY USAMDW (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

I need to be able to verify the serial numbers for proper accountability.
MAJ Hurley agreed to send a picture of them but I have not seen it. A
picture showing the serial numbers was an alternative to having the dongles
on hand to verify their existence. I must see the serial numbers of the
dongles to positively account for the equipment. Thank you.

v/r

5 A
gal Administrator

JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attorney-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization from the Of?ce of The Judge Advocate General,



Page 1313 of2169

02637

Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, February 07, 2013 1:13 PM

To: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
Hurley, Thomas MAJ USARMY (US)

Cc: 'David Coombs'; USARMY USAMDW (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir
We have the Dongles.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 11:03 AM

To: USARMY USAMDW Tooman, Joshua CPT USARMY
Hurley, Thomas MAJ USARMY (US)

Cc: 'David Coombs'; USARMY USAMDW (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Gents,

The reason for this request is that US Army CID is conducting a 100%
inventory of their equipment because of a new hand-receipt holder, and we
have been asked to account for signed property. Thanks!

v/r
MAJ Fein



From: USARMY USAMDW (US)

Sent: Thursday, February 07, 2013 10:58 AM

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

Subject: RE: Question about equipment (UNCLASSIFIED)

Importance: High

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

I still have not received any information on Mount Image Pro Dongles as

Page 1314 of2169

requested weeks ago. Please provide the information as soon as possible.
Thank you!

v/r,



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Tooman, Joshua CPT USARMY (US)

Sent: Tuesday, January 29, 2013 3:03 PM

To: USARMY USAMDW (US)

Cc: Fein, Ashden MAJ USARMY MDW

Hurley, Thomas MAJ USARMY 'David Coombs'
Subject: RE: Question about equipment (UNCLASSIFIED)

We spoke tokg about the Dongles earlier today. We have them and I
believe that ey sent Chief a picture of them.

Thanks,

CPT

USARMY USAMDW

From: USARMY USAMDW (US)

Sent: Tuesday, January 29, 2013 1:38 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
(US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1315 of2169

02638

CPT Tooman,
Good afternoon, Sir. I was wondering if you were able to make any headway
with the Mount Image Pro Dongles? I am trying to clean up the hand receipt

and any assistance you can provide would be greatly appreciated.

Thank you, Sir, and have a nice day.





Paralegal NCO
JFHQ-NCR, MDW



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 4:07 PM

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

Thanks; we'll take a look.

From: USARMY USAMDW (US)
Sent: Wednesday, January 23, 2013 4:05 PM

To: Tooman, Joshua CPT USARMY (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Tooman,

A Mount Image Dongle looks like a very small (about 1 inch long) USB stick
on a nylon lanyard. The USB connector is a Mini-B type. They should have a
rubber cap and sleeve on them, making them each about l"xl/4"xl/4"
rectangular sticks.

I have attached a picture in case I am over-describing it.

Thank you, Sir.





Paralegal NCO
JFHQ-NCR, MDW


From: Tooman, Joshua CPT USARMY (US)
Sent: Wednesday, January 23, 2013 3:52 PM

Page 1316 of2169

02639

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

MP

What is a Mount Image Dongle?

Thanks,

CPT



From: USARMY USAMDW (US)

Sent: Wednesday, January 23, 2013 10:17 AM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
(US)

Subject: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Good morning, Sir,

In an attempt to alleviate any possible confusion, I am a Paralegal NCO
working for MAJ Fein.

I am emailing you in regards to a pair of Dongles that TDS has signed for

from us. MAJ Kemkes originally signed for them, and told me that
you may have taken all of the equipment with you Whe brought onto
the case.

If you could verify that you are in possession of the Mount Image Dongles,
and their numbers (M06, M08), I would greatly appreciate it.

Thank you, Sir.



Page 1317 of2169

02640

02641
Paralegal NCO

JFHQ-NCR, MDW

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1318 of2169

02642

From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW USARMY USAMDW Hurley, Thomas MA.)
LJSARMY (L13)

Cc: "David Coombs"; USARMY USAMDW (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Date: Thursday, February 07, 2013 1:13:16 PM



Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir
We have the Dongles.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, February 07, 2013 11:03 AM

To: USARMY USAMDW Tooman, Joshua CPT USARMY
Hurley, Thomas MAJ USARMY (US)

Cc: 'David Coombs'; USARMY USAMDW (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Gents,

The reason for this request is that US Army CID is conducting a 100%
inventory of their equipment because of a new hand-receipt holder, and we
have been asked to account for signed property. Thanks!

v/r
MAJ Fein



From: USARMY USAMDW (US)

Sent: Thursday, February 07, 2013 10:58 AM

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

Subject: RE: Question about equipment (UNCLASSIFIED)

Importance: High

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

I still have not received any information on Mount Image Pro Dongles as
requested weeks ago. Please provide the information as soon as possible.
Thank you!

v/r,



(6
nge13190f2169

02643

A
gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Tooman, Joshua CPT USARMY (US)

Sent: Tuesday, January 29, 2013 3:03 PM

To: USARMY USAMDW (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
Hurley, Thomas MAJ USARMY 'David Coombs'

Subject: RE: Question about equipment (UNCLASSIFIED)

55

We spoke toglfg about the Dongles earlier today. We have them and I
believe that ey sent Chief a picture of them.

Thanks,
CPT

From: USARMY USAMDW (US)

Sent: Tuesday, January 29, 2013 1:38 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
(US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Tooman,
Good afternoon, Sir. I was wondering if you were able to make any headway

with the Mount Image Pro Dongles? I am trying to clean up the hand receipt
and any assistance you can provide would be greatly appreciated.

Page 1320 of 2169

Thank you, Sir, and have a nice day.





Paralegal NCO
JFHQ-NCR, MDW



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 4:07 PM

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

Thanks; we'll take a look.

From: USARMY USAMDW (US)
Sent: Wednesday, January 23, 2013 4:05 PM

To: Tooman, Joshua CPT USARMY (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Tooman,

A Mount Image Dongle looks like a very small (about 1 inch long) USB stick
on a nylon lanyard. The USB connector is a Mini-B type. They should have a
rubber cap and sleeve on them, making them each about l"xl/4"xl/4"
rectangular sticks.

I have attached a picture in case I am over-describing it.
Thank you, Sir.



Paralegal NCO
JFHQ-NCR, MDW



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 3:52 PM

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

5%

Page 1321 of2169

02644

02645

What is a Mount Image Dongle?

Thanks,

CPT



From: USARMY USAMDW (US)

Sent: Wednesday, January 23, 2013 10:17 AM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
(US)

Subject: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Good morning, Sir,

In an attempt to alleviate any possible confusion, I am a Paralegal NCO
working for MAJ Fein.

I am emailing you in regards to a pair of Dongles that TDS has signed for

from us. MAJ Kemkes originally signed for them, and told me that
you may have taken all of the equipment with you Whe brought onto
the case.

If you could verify that you are in possession of the Mount Image Dongles,
and their numbers (M06, M08), I would greatly appreciate it.

Thank you, Sir.


Paralegal NCO

JFHQ-NCR, MDW

Page 1322 of 2169

02646

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1323 of 2169

02647

From: Fein, Ashden MAJ USARMY MDW (US)

To: USARMY USAMDW TQQman ,(ggmga ,1ng Hurley Thomas MAJ


Cc: "David Coombs"; USARMY USAMDW (US)

Bcc= us ;?_Mow
CIV Mitroka, Katherine CPT USARMY Morrow, JoDean (Joe) CPT

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



Subject: RE: Question about equipment (UNCLASSIFIED)
Date: Thursday, February 07, 2013 11:02:00 AM
Gents,

The reason for this request is that US Army CID is conducting a 100%
inventory of their equipment because of a new hand-receipt holder, and we
have been asked to account for signed property. Thanks!

v/r
MAJ Fein



From: USARMY USAMDW (US)

Sent: Thursday, February 07, 2013 10:58 AM

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

Subject: RE: Question about equipment (UNCLASSIFIED)

Importance: High

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,
I still have not received any information on Mount Image Pro Dongles as
requested weeks ago. Please provide the information as soon as possible.

Thank you!

v/r

5 A
gal Administrator

JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,

Page 1324 of 2169

02648

including attomey-client or attorney work product privileged information.
This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Tooman, Joshua CPT USARMY (US)

Sent: Tuesday, January 29, 2013 3:03 PM

To: USARMY USAMDW (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
Hurley, Thomas MAJ USARMY 'David Coombs'

Subject: RE: Question about equipment (UNCLASSIFIED)

55

We spoke to Chielfg about the Dongles earlier today. We have them and I
believe that MAJ ey sent Chief a picture of them.

Thanks,
CPT

From: USARMY USAMDW (US)

Sent: Tuesday, January 29, 2013 1:38 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
(US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Tooman,

Good afternoon, Sir. I was wondering if you were able to make any headway
with the Mount Image Pro Dongles? I am trying to clean up the hand receipt
and any assistance you can provide would be greatly appreciated.

Thank you, Sir, and have a nice day.



Paralegal NCO
JFHQ-NCR, MDW


From: Tooman, Joshua CPT USARMY (US)
Sent: Wednesday, January 23, 2013 4:07 PM

Page 1325 of 2169

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

Thanks; we'll take a look.



From: USARMY USAMDW (US)
Sent: Wednesday, January 23, 2013 4:05 PM

To: Tooman, Joshua CPT USARMY (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Tooman,

A Mount Image Dongle looks like a very small (about 1 inch long) USB stick
on a nylon lanyard. The USB connector is a Mini-B type. They should have a
rubber cap and sleeve on them, making them each about l"xl/4"xl/4"
rectangular sticks.

I have attached a picture in case I am over-describing it.

Thank you, Sir.






Paralegal NCO
JFHQ-NCR, MDW



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 3:52 PM

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

55

What is a Mount Image Dongle?

Thanks,

CPT



From: USARMY USAMDW (US)

Sent: Wednesday, January 23, 2013 10:17 AM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW

Page 1326 of 2169

02649

(US)
Subject: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Good morning, Sir,

In an attempt to alleviate any possible confusion, I am a Paralegal NCO
working for MAJ Fein.

I am emailing you in regards to a pair of Dongles that TDS has signed for

from us. MAJ Kemkes originally signed for them, and told me that
you may have taken all of the equipment with you Whe brought onto
the case.

If you could verify that you are in possession of the Mount Image Dongles,
and their numbers (M06, M08), I would greatly appreciate it.

Thank you, Sir.

Paralegal NCO

JFHQ-NCR, MDW

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED

Page 1327 of 2169

02650

02651

Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1328 of 2169

02652





From: Fein, Ashden MAJ USARMY MDW (US)

To: David (bombs; r Th MA ARMY Tooman, Joshua ,1 (PT 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_xusmw us

Subject: Security Expert Request

Date: Wednesday, February 06, 2013 5:14:00 PM

Defense,

This week, I spoke with MAJ Hurley and CPT Tooman separately about requesting an additional security expert to
assist the defense with interviews between now and 22 February. If this is something you would like or need,
please submit a written request with detailed justi?cation as soon as possible. The prosecution will ?illy support
the request and expeditiously move it forward for action, but the justi?cation must be detailed and include why your
two experts are not adequate for this period. I am optimistic that the request will be ful?lled, so long as the request
is for a third expert to assist with getting through the next few weeks for your interviews.

Please let me know if you have any questions.

v/r
Ashden

Page 1329 of 2169

02653

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW Prather, Jay USARMY HQDA CIV (US)
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV USARMY ATEC
Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: Availability to Support Defense Witness Interview

Date: Wednesday, February 06, 2013 4:07:28 PM





Roger. Thanks for your help, sir.

Mr. Prather, thank you, as well. We appreciate your ?exibility and willingness to help us out.



Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, February 06, 2013 3:55 PM

To: Tooman, Joshua CPT USARMY Prather, Jay CIV USARMY HQDA CIV
(US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV
USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: Availability to Support Defense Witness Interview

Josh,

I just spoke with Mr. Prather and he is available on Thursday, 14 Feb. He can make the meeting and we do not
object. Please let the Court know in your request to use him that we do not object.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, February 06, 2013 3:44 PM

To: Prather, Jay CIV USARMY HQDA Fein, Ashden MAJ USARMY MDW
CIV (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV
USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: Availability to Support Defense Witness Interview

Mr. Prather

Page 1330 of 2169

02654

I am wondering if you are available to assist the Defense next week with a witness interview. The Court's protective
order requires us to have a security expert with us any time we are going to discuss classi?ed information with a
witness. The Department of State has offered two times during which we can interview Ambassador Kennedy, one
ofthe Government's witnesses: 13 FEB, 1300-1400 or 14 FEB, 1330-1430. Are you available and willing to assist
at either of those times? If so, I will request permission from the Court to have you accompany us.

Thanks,

Josh

Page 1331 of2169

02655



From: Fein, Ashden MAJ USARMY MDW (US)

To: rl Th MA ARMY

Bcc: Morrow, JoDean (Joe) CPT USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Date: Wednesday, February 06, 2013 3:59:00 PM

MAJ Hurley-

I called and left a message on your of?ce phone. If you have time today or tomorrow afternoon, could we chat
again? It?s a follow-up from Monday and I wanted to make sure you guys were good with a few other issues.

Thanks!



From: Hurley, Thomas MAJ USARMY (US)

Sent: Wednesday, February 06, 2013 3:25 PM

To: Fein, Ashden MAJ USARMY MDW USARMY USAMDW (US)

Cc: USARMY CW4 USARMY USAMDW
CIV CIV MAJ USAF (US)

bject: RE: LOA (UNCLASSIFIED)

MAJ Fein
6
Thanks for your consideration of this matter. I hate to be responsible for additional personnel being brought in to
perform additional duties, but it is probably best for the parties to avoid unnecessary confrontation about travel.






MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, February 06, 2013 8:20 PM
To: Hurley, Thomas MAJ USARMY USARMY USAMDW (US)

Cc: USARMY CW4 USARMY USAMDW
CIV CIV MAJ USAF (US)

bject: RE: LOA (UNCLASSIFIED)



MAJ Hurley,

6

This afternoon I discussed the potential effects of this with Chief and realizing that one of our paralegals
would be in your approving chain, I asked Chief- and to reevaluate the best method to process
your travel requests, which does not include a member of the prosec in this case approving/disapproving your
travel or having any other role in your travel.

They decided that it would be more ef?cient and appropriate for the main of?ce to process your travel vice the
prosecution. Please submit any questions or comments about travel, including issues with DTS to - and

(CCed) as your reviewing of?cials. Chief- and Maj -, USAF (CCed) are your
approving of?cials.

Thank you!

v/r
MAJ Fein


From: Hurley, Thomas MAJ USARMY (US)

Page 1332 of 2169

02656

Sent: Wednesday, February 06, 2013 3: 12 PM

To: USARMY USAMDW (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)



(Blanks



v/r

MAJ Hurley



From: USARMY USAMDW (US)

Sent: Wednesday, February 06, 2013 5:36 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

As per the e-mail traf?c below, a decision has been made I regards to your
request for support by_ MDW will take care of the costs
associated with your TDY in support of this case. FYSA, I will be the
approving of?cial for all travel when using the US v. Manning LOA. Thus,
if you have any questions please do not reach out to your command as they do
not control the reviewing or approval processes with this LOA. The LOA is
labeled 13 US MA and it should be located under your CrossOrg
accounting labels. The LOA is loaded already in your pro?le so you can
schedule your travel at your convenience. Thank you.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

Page 1333 of 2169

02657

action in reliance on this information is prohibited. If you received this
email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 11:38 AM

To: USARMY USAMDW (US)
Cc: USARMY CW4 USARMY USAMDW

(US)
Subject: FW: LOA (UNCLASSIFIED)



Please inform MAJ Hurley that_ spoke directly withg-
about the ambiguity in the regulation, rather than waiting for MA urley to
run this issue up through TDS channels. suggested that we will
fund MAJ Hurley's travel under the circumstances of this case.

They agreed that a gaining organization would obviously not be responsible

for travel costs incurred by a defense counsel who had been previously

detailed, but that it was a policy decision on whether it would be better

for USATDS to continue to be responsible after a PCS from USATDS or whether
the burden should automatically shift to the convening authority as it would

in the case where the IMC was not assigned to TDS when appointed.

Since the entire cost assessed for these court-martial proceedings will

ultimately be analyzed and executed by the Army Budget Of?ce IAW HQDA EXORD
206-11, it makes more practical sense to consolidate the costs at this

Headquarters rather than require USATDS to submit a UFR for any

extraordinary costs a second non-TDS IMC detailed for this complex

case) or require another IMC request to be processed through this GCMCA to
determine "reasonable availability" from the perspective of the gaining

organization.

Accordingly, please add MAJ Hurley to the line of accounting as quickly as
possible to ensure he can complete any related travel without delay. As CPT
Tooman remains assigned to TDS, his LOA remains at TDS. In addition, please
make any necessary coordination with the TDS legal administrator as well.

Please contact me if you have any questions.

v/r



puty Staff Judge Advocate
JFHQ-NCR and US. Army Military District of Washington




Fort Lesley J. McNair, DC 20319-5058



Page 1334 of 2169








From: USARMY USAMDW (US)
Sent: Tuesday, February 05, 2013 4:05 PM

To: USARMY USAMDW (US)

Cc CW4 USARMY USAMDW (US)

Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

Below is the issue we discussed in regards to funding of TDS counsel in the

case of US V. Manning. As far as the information you requested, MAJ Hurley
was requested as an IMC in 25 April 2012. When the IMC request was approved
by the CA he was part of TDS. MAJ Hurley was assigned to the Military
Commissions on 2 July 2012. As far as CPT Tooman is concerned he was
requested as an IMC but has never left TDS and is currently assigned to the

TDS of?ce at Ft. Belvoir.

v/r,



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 2:42 PM

To: USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

55

I would direct your attention to AR 27-10, paragraph Therein, it

Page 1335 of 2169

02658

02659

is indicated that "convening authorities will continue to
appearance of individual military counsel not currently assigned to

I don't mean to brag, and I don't mean to boast, but I qualify under both
prongs of that regulatory language. in June - left TDS in July.) I
would go farther and say that the CA should pay for the travel of both CPT
Tooman and myself because we are both post-referral IMC requests that were
granted by the CA. But CPT Tooman and TDS can work that out internally or
with the CA or his designated rep (I'm guessing that's you).

Anyway. My SSN is_. Please tell me when it's loaded.
Thanks.

MAJ Hurley



From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 6:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

MDW does not fund TDS attomeys' travel for this case or any other. The
only funding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any funding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
further questions please feel free to contact me at your convenience.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization from the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this

Page 1336 of 2169

02660

information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: Hurley, Thomas MAJ USARMY (US)
Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief

Would you add the Manning LOA to my cross org
Thanks.

Tom Hurley

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1337 of 2169

02661

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman, Joshua QPT USARMY Pr IV ARMY DA CIV (US)
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW US Over aard An el CPT USARMY US Wh te Hunter CPT USARMY US von Elten
Alexander (Alec) CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV USARMY ATEC
Smith, Lillian CIV USARMY HQDA ITA EM (US)





Bee:
USARMY
Mitroka, Katherine CPT USARMY (US)
Subject: RE: Availability to Support Defense Witness Interview
Date: Wednesday, February 06, 2013 3:55:00 PM
I mportance: High
Josh,

I just spoke with Mr. Prather and he is available on Thursday, 14 Feb. He can make the meeting and we do not
object. Please let the Court know in your request to use him that we do not object.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, February 06, 2013 3:44 PM

To: Prather, Jay CIV USARMY HQDA Fein, Ashden MAJ USARMY MDW
CIV (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV
USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: Availability to Support Defense Witness Interview

Mr. Prather

I am wondering if you are available to assist the Defense next week with a witness interview. The Court's protective
order requires us to have a security expert with us any time we are going to discuss classi?ed information with a
witness. The Department of State has offered two times during which we can interview Ambassador Kennedy, one
ofthe Government's witnesses: 13 FEB, 1300-1400 or 14 FEB, 1330-1430. Are you available and willing to assist
at either of those times? If so, I will request permission from the Court to have you accompany us.

Thanks,

Josh

Page 1338 of 2169

02662





From: Fein, Ashden MAJ USARMY MDW (US)

To: ngman, Joshua QPT USARMY Pr IV ARMY DA CIV (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV USARMY ATEC
Smith, Lillian CIV USARMY HQDA ITA EM (US)

Bcc:
1&1; USARMY

Mitroka, Katherine CPT USARMY (US)

Subject: RE: Availability to Support Defense Witness Interview

Date: Wednesday, February 06, 2013 3:49:00 PM

Gents,

I just called Mr. Prather's cell phone and left a message to see if he is
available. If he is available, the United States supports this limited
assistance by the Court's security of?cer and will not object with the

Court.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, February 06, 2013 3:44 PM

To: Prather, Jay CIV USARMY HQDA Fein, Ashden MAJ USARMY MDW

CIV (US)

Cc: Hurley, Thomas MAJ USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV USARMY ATEC
Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: Availability to Support Defense Witness Interview

Mr. Prather

I am wondering if you are available to assist the Defense next week with a
witness interview. The Court's protective order requires us to have a

security expert with us any time we are going to discuss classi?ed

information with a witness. The Department of State has offered two times
during which we can interview Ambassador Kennedy, one of the Government's
witnesses: 13 FEB, 1300-1400 or 14 FEB, 1330-1430. Are you available and
willing to assist at either of those times? If so, I will request

permission from the Court to have you accompany us.

Thanks,

Josh

Page 1339 of 2169

02663





From: Tooman, Joshua CPT USARMY (US)

To: Prather, (Jay QIV LJSARMY HQDA in A MA ARMY MDW CIV (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten
Alexander (Alec) CPT USARMY Hall, Cassius CIV Ganiel, Charles CIV USARMY ATEC
Smith, Lillian CIV USARMY HQDA EM (US)

Subject: Availability to Support Defense Witness Interview

Date: Wednesday, February 06, 2013 3:44:30 PM

Mr. Prather

I am wondering if you are available to assist the Defense next week with a witness interview. The Court's protective
order requires us to have a security expert with us any time we are going to discuss classi?ed information with a
witness. The Department of State has offered two times during which we can interview Ambassador Kennedy, one
ofthe Government's witnesses: 13 FEB, 1300-1400 or 14 FEB, 1330-1430. Are you available and willing to assist
at either of those times? If so, I will request permission from the Court to have you accompany us.

Thanks,

Josh

Page 1340 of 2169

02664





From: Hurley, Thomas MAJ USARMY (US)

To: in A MA ARMY MDW USARMY USAMDW (US)

Cc: CW4 USARMY USAMDW (US): CIV
4&1; MAJ USAF (US)

Subject: RE: LOA (UNCLASSIFIED)

Date: Wednesday, February 06, 2013 3:25:18 PM

MAJ Fein

Thanks for your consideration of this matter. I hate to be responsible for additional personnel being brought in to
perform additional duties, but it is probably best for the parties to avoid unnecessary confrontation about travel.

MAJ Hurley



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, February 06, 2013 8:20 PM
To: Hurley, Thomas MAJ USARMY USARMY USAMDW (US)

Cc: USARMY CW4 USARMY USAMDW
CIV CIV (US) MAJ USAF (US)

bject: RE: LOA (UNCLASSIFIED)

MAJ Hurley,
6
This afternoon I discussed the potential effects of this with Chief and realizing that one of our paralegals
would be in your approving chain, I asked Chief- and to reevaluate the best method to process
your travel requests, which does not include a member of the prosec in this case approving/disapproving your
travel or having any other role in your travel.






They decided that it would be more ef?cient and appropriate for the main of?ce to process your travel vice the
prosecution. Please submit any questions or comments about travel, including issues with DTS to - and

(CCed) as your reviewing of?cials. Chief-and Maj -, USAF (CCed) are your

approving of?cials.
Thank you!

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Wednesday, February 06, 2013 3: 12 PM

To: USARMY USAMDW (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)



(Blanks!


v/r
MAJ Hurley

From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 5:36 PM

Page 1341 of2169

02665

To: Hurley, Thomas MAJ USARMY (US)
Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

As per the e-mail traf?c below, a decision has been made I regards to your
request for support by_ MDW will take care of the costs
associated with your TDY in support of this case. FYSA, I will be the
approving of?cial for all travel when using the US v. Manning LOA. Thus,
if you have any questions please do not reach out to your command as they do
not control the reviewing or approval processes with this LOA. The LOA is
labeled 13 US and it should be located under your CrossOrg
accounting labels. The LOA is loaded already in your pro?le so you can
schedule your travel at your convenience. Thank you.

v/r,



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 11:38 AM

To: USARMY USAMDW (US)
Cc: USARMY CW4 USARMY USAMDW

(US)
Subject: FW: LOA (UNCLASSIFIED)



Page 1342 of 2169

02666

Please inform MAJ Hurley that_ spoke directly withg-
about the ambiguity in the regulation, rather than waiting for MA urley to
run this issue up through TDS channels. suggested that we will
fund MAJ Hurley's travel under the circumstances of this case.

They agreed that a gaining organization would obviously not be responsible

for travel costs incurred by a defense counsel who had been previously

detailed, but that it was a policy decision on whether it would be better

for USATDS to continue to be responsible after a PCS from USATDS or whether
the burden should automatically shift to the convening authority as it would

in the case where the IMC was not assigned to TDS when appointed.

Since the entire cost assessed for these court-martial proceedings will

ultimately be analyzed and executed by the Army Budget Of?ce IAW HQDA EXORD
206-11, it makes more practical sense to consolidate the costs at this

Headquarters rather than require USATDS to submit a UFR for any

extraordinary costs a second non-TDS IMC detailed for this complex

case) or require another IMC request to be processed through this GCMCA to
determine "reasonable availability" from the perspective of the gaining

organization.

Accordingly, please add MAJ Hurley to the line of accounting as quickly as
possible to ensure he can complete any related travel without delay. As CPT
Tooman remains assigned to TDS, his LOA remains at TDS. In addition, please
make any necessary coordination with the TDS legal administrator as well.

Please contact me if you have any questions.

v/r



puty Staff Judge Advocate
JFHQ-NCR and US. Army Military District of Washington





Fort Lesley J. McNair, DC 20319-5058



From: USARMY USAMDW (US)
Sent: Tuesday, February 05, 2013 4:05 PM

To: USARMY USAMDW (US)

Cc CW4 USARMY USAMDW (US)
Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,
Below is the issue we discussed in regards to funding of TDS counsel in the

case of US v. Manning. As far as the information you requested, MAJ Hurley
was requested as an IMC in 25 April 2012. When the IMC request was approved

Page 1343 of 2169

by the CA he was part of TDS. MAJ Hurley was assigned to the Military
Commissions on 2 July 2012. As far as CPT Tooman is concerned he was
requested as an IMC but has never left TDS and is currently assigned to the
TDS of?ce at Ft. Belvoir.

v/r,



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 2:42 PM

To: USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

55

I would direct your attention to AR 27-10, paragraph Therein, it
is indicated that "convening authorities will continue to
appearance of individual military counsel not currently assigned to

I don't mean to brag, and I don't mean to boast, but I qualify under both
prongs of that regulatory language. in June - left TDS in July.) I
would go farther and say that the CA should pay for the travel of both CPT
Tooman and myself because we are both post-referral IMC requests that were

granted by the CA. But CPT Tooman and TDS can work that out internally or
with the CA or his designated rep (I'm guessing that's you).

Anyway. My SSN is_. Please tell me when it's loaded.
Thanks.

MAJ Hurley

Page 1344 of 2169

02667

02668

From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 6:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

MDW does not fund TDS attomeys' travel for this case or any other. The
only funding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any funding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
?irther questions please feel ?ee to contact me at your convenience.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and





From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief

Page 1345 of 2169

02669

Would you add the Manning LOA to my cross org

Thanks.

Tom Hurley

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1346 of 2169

02670

From: Fein, Ashden MAJ USARMY MDW (US)

















To: rl Th MA ARMY USARMY USAMDW (US)
Cc: USARMY (US) CW4 USARMY USAMDW (US): CIV
CIV MAJ USAF (US)

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

Subject: RE: LOA (UNCLASSIFIED)

Date: Wednesday, February 06, 2013 3:20:00 PM

MAJ Hurley,

This afternoon I discussed the potential effects of this with Chief and realizing that one of our paralegals

would be in your approving chain, I asked Chief - and to reevaluate the best method to process
your travel requests, which does not include a member of the prosec in this case approving/disapproving your
travel or having any other role in your travel.

They decided that it would be more ef?cient and appropriate for the main of?ce to process your travel vice the
prosecution. Please submit any questions or comments about travel, including issues with DTS to - and

(CCed) as your reviewing of?cials. Chief- and Maj -, USAF (CCed) are your
approving of?cials.

Thank you!

v/r
MAJ Fein



From: Hurley, Thomas MAJ USARMY (US)

Sent: Wednesday, February 06, 2013 3: 12 PM

To: USARMY USAMDW (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)



(Blanks!


v/r
MAJ Hurley

From: USARMY USAMDW (US)

Sent: Wednesday, February 06, 2013 5:36 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)
Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

As per the e-mail traf?c below, a decision has been made I regards to your
request for support by_ MDW will take care of the costs

Page 1347 of 2169

associated with your TDY in support of this case. FYSA, I will be the
approving of?cial for all travel when using the US V. Manning LOA. Thus,
if you have any questions please do not reach out to your command as they do
not control the reviewing or approval processes with this LOA. The LOA is
labeled 13 US and it should be located under your CrossOrg
accounting labels. The LOA is loaded already in your pro?le so you can
schedule your travel at your convenience. Thank you.

v/r,



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 11:38 AM

To: USARMY USAMDW (US)
Cc: USARMY CW4 USARMY USAMDW

(US
Subject: FW: LOA (UNCLASSIFIED)

Please inform MAJ Hurley that_ spoke directly with%

about the ambiguity in the regulation, rather than waiting for MA url to
run this issue up through TDS channels. suggested that we will
?nd MAJ Hurley's travel under the circumstances of this case.

They agreed that a gaining organization would obviously not be responsible

for travel costs incurred by a defense counsel who had been previously

detailed, but that it was a policy decision on whether it would be better

for USATDS to continue to be responsible after a PCS ?om USATDS or whether
the burden should automatically shift to the convening authority as it would

in the case where the IMC was not assigned to TDS when appointed.

Page 1348 of 2169

02671

02672

Since the entire cost assessed for these court-martial proceedings will

ultimately be analyzed and executed by the Army Budget Of?ce IAW HQDA EXORD
206-11, it makes more practical sense to consolidate the costs at this

Headquarters rather than require USATDS to submit a UFR for any

extraordinary costs a second non-TDS IMC detailed for this complex

case) or require another IMC request to be processed through this GCMCA to
determine "reasonable availability" from the perspective of the gaining

organization.

Accordingly, please add MAJ Hurley to the line of accounting as quickly as
possible to ensure he can complete any related travel without delay. As CPT
Tooman remains assigned to TDS, his LOA remains at TDS. In addition, please
make any necessary coordination with the TDS legal administrator as well.

Please contact me if you have any questions.

v/r



puty Staff Judge Advocate
JFHQ-NCR and US. Army Military District of Washington




Fort Lesley J. McNair, DC 20319-5058






From: USARMY USAMDW (US)
Sent: Tuesday, February 05, 2013 4:05 PM

To: USARMY USAMDW (US)

Cc: CW4 USARMY USAMDW (US)

Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

Below is the issue we discussed in regards to funding of TDS counsel in the

case of US v. Manning. As far as the information you requested, MAJ Hurley
was requested as an IMC in 25 April 2012. When the IMC request was approved
by the CA he was part of TDS. MAJ Hurley was assigned to the Military
Commissions on 2 July 2012. As far as CPT Tooman is concerned he was
requested as an IMC but has never left TDS and is currently assigned to the

TDS of?ce at Ft. Belvoir.

v/r,



JA

Page 1349 of 2169

02673

Legal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 2:42 PM

To: USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)



I would direct your attention to AR 27-10, paragraph Therein, it
is indicated that "convening authorities will continue to
appearance of individual military counsel not currently assigned to

I don't mean to brag, and I don't mean to boast, but I qualify under both
prongs of that regulatory language. in June - left TDS in July.) I
would go farther and say that the CA should pay for the travel of both CPT
Tooman and myself because we are both post-referral IMC requests that were
granted by the CA. But CPT Tooman and TDS can work that out internally or
with the CA or his designated rep (I'm guessing that's you).

Anyway. My SSN is_. Please tell me when it's loaded.
Thanks.

MAJ Hurley



From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 6:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

Page 1350 of 2169

MDW does not fund TDS attomeys' travel for this case or any other. The
only funding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any funding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
further questions please feel free to contact me at your convenience.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization from the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: Hurley, Thomas MAJ USARMY (US)
Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief
Would you add the Manning LOA to my cross org
Thanks.

Tom Hurley

Page 1351 of2169

02674

02675

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1352 of 2169

02676



From: Hurley, Thomas MAJ USARMY (US)

To: USARMY USAMDW (US)

Cc: Fein Ashden MAJ USARMY MDW USARMY (US)
Subject: RE: LOA (UNCLASSIFIED)

Date: Wednesday, February 06, 2013 3:12:44 PM

(Blanks!

v/r

MAJ Hurley



From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 5:36 PM
To: Hurley, Thomas MAJ USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY (US)

Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

As per the e-mail traf?c below, a decision has been made I regards to your
request for support by_ MDW will take care of the costs
associated with your TDY in support of this case. FYSA, I will be the
approving of?cial for all travel when using the US v. Manning LOA. Thus,
if you have any questions please do not reach out to your command as they do
not control the reviewing or approval processes with this LOA. The LOA is
labeled 13 US and it should be located under your CrossOrg
accounting labels. The LOA is loaded already in your pro?le so you can
schedule your travel at your convenience. Thank you.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense

Page 1353 of 2169

02677

without prior authorization from the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: USARMY USAMDW (US)
Sent: Wednesday, February 06, 2013 11:38 AM

To: USARMY USAMDW (US)
Cc: USARMY CW4 USARMY USAMDW

(US)
Subject: FW: LOA (UNCLASSIFIED)

5

Please inform MAJ Hurley that_ spoke directly with%

about the ambiguity in the regulation, rather than waiting for MA url to
run this issue up through TDS channels. suggested that we will
fund MAJ Hurley's travel under the circumstances of this case.

They agreed that a gaining organization would obviously not be responsible

for travel costs incurred by a defense counsel who had been previously

detailed, but that it was a policy decision on whether it would be better

for USATDS to continue to be responsible after a PCS from USATDS or whether
the burden should automatically shift to the convening authority as it would

in the case where the IMC was not assigned to TDS when appointed.

Since the entire cost assessed for these court-martial proceedings will

ultimately be analyzed and executed by the Army Budget Of?ce IAW HQDA EXORD
206-11, it makes more practical sense to consolidate the costs at this

Headquarters rather than require USATDS to submit a UFR for any

extraordinary costs a second non-TDS IMC detailed for this complex

case) or require another IMC request to be processed through this GCMCA to
determine "reasonable availability" from the perspective of the gaining

organization.

Accordingly, please add MAJ Hurley to the line of accounting as quickly as
possible to ensure he can complete any related travel without delay. As CPT
Tooman remains assigned to TDS, his LOA remains at TDS. In addition, please
make any necessary coordination with the TDS legal administrator as well.

Please contact me if you have any questions.

v/r



puty Staff Judge Advocate
JFHQ-NCR and US. Army Military District of Washington




Fort Lesley J. McNair, DC 20319-5058



Page 1354 of 2169








From: USARMY USAMDW (US)
Sent: Tuesday, February 05, 2013 4:05 PM

To: USARMY USAMDW (US)

Cc CW4 USARMY USAMDW (US)

Subject: FW: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Gentlemen,

Below is the issue we discussed in regards to funding of TDS counsel in the

case of US V. Manning. As far as the information you requested, MAJ Hurley
was requested as an IMC in 25 April 2012. When the IMC request was approved
by the CA he was part of TDS. MAJ Hurley was assigned to the Military
Commissions on 2 July 2012. As far as CPT Tooman is concerned he was
requested as an IMC but has never left TDS and is currently assigned to the

TDS of?ce at Ft. Belvoir.

v/r,



JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization ?om the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 2:42 PM

To: USARMY USAMDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Page 1355 of 2169

02678

02679

RE

I would direct your attention to AR 27-10, paragraph Therein, it
is indicated that "convening authorities will continue to
appearance of individual military counsel not currently assigned to

I don't mean to brag, and I don't mean to boast, but I qualify under both
prongs of that regulatory language. in June - left TDS in July.) I
would go farther and say that the CA should pay for the travel of both CPT
Tooman and myself because we are both post-referral IMC requests that were
granted by the CA. But CPT Tooman and TDS can work that out internally or
with the CA or his designated rep (I'm guessing that's you).

Anyway. My SSN is_ Please tell me when it's loaded.
Thanks.

MAJ Hurley



From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 6:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

MDW does not fund TDS attomeys' travel for this case or any other. The
only funding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any funding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
further questions please feel free to contact me at your convenience.

v/r,
JA

gal Administrator
JFHQ-NCR, MDW



The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attomey-client or attorney work product privileged information.

Page 1356 of 2169

02680

This information may not be released outside of the Department of Defense
without prior authorization from the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any
action in reliance on this information is prohibited. If you received this
email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and


From: Hurley, Thomas MAJ USARMY (US)
Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief

Would you add the Manning LOA to my cross org
Thanks.

Tom Hurley

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1357 of 2169

02681

From: Fein, Ashden MAJ USARMY MDW (US)

To: "David (bombs'; rl Th MA ARMY

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







Bcc:
1&1; USARMY
Mitroka, Katherine CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Whyte, Hunter CPT USARMY (US)
Subject: RE: PFC BM
Date: Tuesday, February 05, 2013 5:16:00 PM
David,

We will start coordinating. Thank you.

v/r

Ashden



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Tuesday, February 05, 2013 5:16 PM

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

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

Subject: PFC BM

Ashden,

Please have PFC BM brought to the Fort Meade TDS Of?ce at 0930 on 25
February 2012. I anticipate the need to meet with him until 1600. Thank
you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1358 of 2169

02682



From: David Coombs

To: Fain, MAJ LJSARMY MDW Th MA ARMY

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

Subject: PFC BM

Date: Tuesday, February 05, 2013 5:15:47 PM

Ashden,

Please have PFC BM brought to the Fort Meade TDS Of?ce at 0930 on 25
February 2012. I anticipate the need to meet with him until 1600. Thank
you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1359 of 2169

02683

From: Fein, Ashden MAJ USARMY MDW (US)

To: USARMY USAMDW
Cc: USARMY (US)

Bcc: USARMY USAMDW (US)

Subject: RE: LOA (UNCLASSIFIED)

Date: Tuesday, February 05, 2013 3:32:00 PM



Gents- This appears to be an issue that requires a determination by the

proper authority so that? does not violate any ?scal rules as the
approving of?cial.

Chief? please coordinate immediately with Chief - and the DSJA and
?gure out what the proper COA is under AR 27- 10 and OTJAG's interpretation.

Thanks!

v/r
MAJ Fein



From: USARMY USAMDW (US)

Sent: Tuesday, February 05, 2013 1:48 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: LOA (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir,

MDW does not ?nd TDS attorneys' travel for this case or any other. The
only ?inding we provide is for the TDS experts who are unique to this case,
and appointed by the CA, because of its complexity and its requirements.
Please reach back to HQ, TDS for TDY support and if they have any ?inding
issues, due to shrinking budgets or other scenarios, have their legal
administrator get a hold of me so we can discuss other avenues. If you have
?irther questions please feel ?ee to contact me at your convenience.

v/r

5 A
gal Administrator

JFHQ-NCR, MDW



Page 1360 of 2169

02684

The information contained in this email and any accompanying
attachments may contain Freedom of Information Act protected information,
including attorney-client or attorney work product privileged information.

This information may not be released outside of the Department of Defense
without prior authorization from the Of?ce of The Judge Advocate General,
Department of the Army. If you are not the intended recipient of this
information, any disclosure, copying, distribution, or the taking of any

action in reliance on this information is prohibited. If you received this

email in error, please notify this of?ce immediately by return email (see 5
U.S.C. 552 and Army Regulations 25-55 and



From: Hurley, Thomas MAJ USARMY (US)

Sent: Tuesday, February 05, 2013 11:07 AM

To: USARMY USAMDW (US)
Cc: USARMY (US)

Subject: LOA

Chief

Would you add the Manning LOA to my cross org

Thanks.

Tom Hurley

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1361 of2169

02685

From: Hurley, Thomas MAJ OSD OMC Defense

To:

Cc: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV (US)
Subject: RE: Phone Call

Date: Tuesday, February 05, 2013 9:37:20 AM





You should have the info now. Can you double check that you do?
Thanks.
Tom



From

Sent: Monday, February 04, 2013 3:37 PM

To: Hurley, Thomas MAJ OSD OMC Defense

Cc: Fein, Ashden MAJ USARMY MDW
Subject: RE: Phone Call

Thanks. Correct. The sooner Mr. Hall can get that info to me, the sooner I can get the visit request in.

Joe

Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Monday, February 04, 2013 1:18 PM

To:
Cc: Fein, Ashden MAJ USARMY MDW

Subject: RE: Phone Call
Joe
Mr. Hall has an IC badge. I do not.

My SSN is?.
Mr. Hall is cc'd on this email.

The SMO code we need to pass our clearances to is FBIDC for only TS information, is that right?

Page 1362 of 2169

02686

Thanks.
MAJ Hurley



From: .

Sent: Friday, February 01, 2013 10:58 AM

To: Hurley, Thomas MAJ OSD OMC Defense
Cc: Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: Phone Call

Tom-

Also, I need SSNs for both you and Mr. Hall for the visitor request paperwork. Do you both have IC badges? If
not, please pass TS clearances for both of you - it will make it easier for the visitor approval paperwork.

Thanks.



Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From:

Sent: Friday, February 01, 2013 10:55 AM

To: 'Hurley, Thomas MAJ OSD OMC Defense'
Cc: 'Fein, Ashden MAJ USARMY MDW
Subject: RE: Phone Call

Tom-

2/ 5 at 9am at Quantico it is. I need your security manager to pass clearances for you and Mr. Hall via JPAS utilizing
SMO Code FBIDC for up to TS, and FBIDC2 if SCI will be discussed ASAP. Have you been down here before?

We are on the FBI Academy complex at MCBQ, in the Engineering Research Facility. Here are directions:

1) I-95 to exit 148 (Russell Road, Marine Corps Base)

2) Turn right at end of ramp onto Russell Road

3) Continue on Russell Road until you hit gate for entry onto Marine Corps Base.

4) Russell Road, once you get past the gate, will change names to

5) Stay on MCB l. WATCH YOUR SPEED LIMIT - the Marine Corps Police are aggressive and unforgiving with
respect to speed limits. Remain on the main road. You will pass a ?re station on your left.

6) About 1400 feet after the ?re station, the main road (MCB 1) will change to MBC4 right after a clearing in the
woods on your left. Remain on MCB4. Shortly after the change ?om to MCB4 you will pass a
maintenance yard on your left, and a shooting range and water tower on your right.

7) Shortly after that, you will come up to the road leading to the East Gate to the FBI Complex. You will see FBI

Page 1363 of 2169

02687

signs on the road. Turn right to the east gate. Provide your ID to the FBI Police of?cers in the booth.

8) After you clear the booth, make your second left onto J. Edgar Hoover Road.

9) Take that to the 2nd left and turn into the driveway. You should see signs for the Engineering Research Facility.
10) Go through the gate and drive toward the front door of the building. There are visitor spots right in front of the
main door that you can park in. Go inside to security, and when you arrive, they will call me.



Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From: Hurley, Thomas MAJ OSD OMC Defens?

Sent: Wednesday, January 30, 2013 9:40 AM
To:
Subject: RE: Phone Call



It absolutely does work for me. I will be bringing with me (at least) Mr. Cassius Hall. He's our security expert and,
by order of the court, he's got to be there every time we talk about classi?ed stuff with a witness.

Sorry it took me so long to get back to you.

Tom



From: .

Sent: Friday, January 25, 2013 5:28 PM

To: Hurley, Thomas MAJ OSD OMC Defense
Subject: RE: Phone Call

Tom-

The way it's shaping up it looks like we'll need to set up the meeting for Tues, 2/5 at 0900 here at Quantico. Does
that work for you preliminarily?

Also,_ is now based in South A?icathe next 2 weeks. has also
transferred to Houston, but we can try to get him in.

I'm still trying to get the clearance info squared away.



Assistant General Counsel

Page 1364 of 2169

02688

Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Wednesday, January 23, 2013 4:49 PM
To:
Subject: Phone Call

Joe
Here is my info.

Take care.
Tom

Page 1365 of 2169

02689

From: Hurley, Thomas MAJ USARMY (US)

To: CAPT USMC (US)

Cc: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Overgaard, Angel CPT USARMY Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: USMC POC info

Date: Monday, February 04, 2013 1:24:34 PM



Capt

Good to speak with you on the phone this morning. Did you get the summary of MG McKenzie's testimony from
the government?

Thanks.

MAJ Hurley



From:

Sent: Monday, February 04, 2013 1:29 PM

To: Hurley, Thomas MAJ USARMY (US)

Cc: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Fein, Ashden MAJ USARMY MDW
(US)

Subject: RE: USMC POC info

MAJ Hurley,

Good morning, Sir. I'll be sitting in on the defense interview of MajGen McKenzie. I'm having an introductory
meeting with MajGen McKenzie this afternoon at 1300. Do you have a few minutes this morning to touch base? If
so, I can give you a call when you're available, or you can call me my direct number).
Thank you, Sir.

Very Respectfully,

USMC
Research and Civil Law Branch (JAR)
Judge Advocate Division, HQMC



From: Fein, Ashden MAJ USARMY MDW

Sent: Monday, February 04, 2013 8: 12 AM

To: Hurley, Thomas MAJ USARMY (US)

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

Subject: USMC POC info

Gents,
Good morning.
Capt??- The military defense counsel who would likely be interviewing

Maj McKenzie is MAJ Tom Hurley (in the T0 line). The other defense
counsel are Mr. David Coombs and CPT Josh Tooman (CC line).

Page 1366 of 2169

02690

MAJ Hurley-_ is the new POC for MajGen McKenzie.

V/r
MAJ Fein

Page 1367 of 2169

02691

From: Hurley, Thomas MAJ OSD OMC Defense

To:

Cc: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV (US)
Subject: RE: Phone Call

Date: Monday, February 04, 2013 1:19:07 PM





Mr. Hall has an IC badge. I do not.

My SSN is
Mr. Hall is cc'd on this email.

The SMO code we need to pass our clearances to is FBIDC for only TS information, is that right?
Thanks.
MAJ Hurley



From:

Sent: Friday, February 01, 2013 10:58 AM

To: Hurley, Thomas MAJ OSD OMC Defense
Cc: Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: Phone Call

Tom-

Also, I need SSNs for both you and Mr. Hall for the visitor request paperwork. Do you both have IC badges? If
not, please pass TS clearances for both of you - it will make it easier for the visitor approval paperwork.

Thanks.



Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From:

Sent: Friday, February 01, 2013 10:55 AM

To: 'Hurley, Thomas MAJ OSD OMC Defense'
Cc: 'Fein, Ashden MAJ USARMY MDW
Subject: RE: Phone Call

Page 1368 of 2169

02692

Tom-

2/ 5 at 9am at Quantico it is. I need your security manager to pass clearances for you and Mr. Hall via JPAS utilizing
SMO Code FBIDC for up to TS, and FBIDC2 if SCI will be discussed ASAP. Have you been down here before?

We are on the FBI Academy complex at MCBQ, in the Engineering Research Facility. Here are directions:

1) I-95 to exit 148 (Russell Road, Marine Corps Base)

2) Turn right at end of ramp onto Russell Road

3) Continue on Russell Road until you hit gate for entry onto Marine Corps Base.

4) Russell Road, once you get past the gate, will change names to

5) Stay on MCB l. WATCH YOUR SPEED LIMIT - the Marine Corps Police are aggressive and unforgiving with
respect to speed limits. Remain on the main road. You will pass a ?re station on your left.

6) About 1400 feet after the ?re station, the main road (MCB 1) will change to MBC4 right after a clearing in the
woods on your left. Remain on MCB4. Shortly after the change ?om to MCB4 you will pass a
maintenance yard on your left, and a shooting range and water tower on your right.

7) Shortly after that, you will come up to the road leading to the East Gate to the FBI Complex. You will see FBI
signs on the road. Turn right to the east gate. Provide your ID to the FBI Police of?cers in the booth.

8) After you clear the booth, make your second left onto J. Edgar Hoover Road.

9) Take that to the 2nd left and turn into the driveway. You should see signs for the Engineering Research Facility.
10) Go through the gate and drive toward the front door of the building. There are visitor spots right in front of the
main door that you can park in. Go inside to security, and when you arrive, they will call me.



Science Technology Law Unit
Federal Bureau of Investigation





Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Wednesday, January 30, 2013 9:40 AM
To:
Subject: RE: Phone Call



It absolutely does work for me. I will be bringing with me (at least) Mr. Cassius Hall. He's our security expert and,
by order of the court, he's got to be there every time we talk about classi?ed stuff with a witness.

Sorry it took me so long to get back to you.
Tom


From
Sent: Friday, January 25, 2013 5:28 PM

Page 1369 of 2169

02693

To: Hurley, Thomas MAJ OSD OMC Defense
Subject: RE: Phone Call

Tom-

The way it's shaping up it looks like we'll need to set up the meeting for Tues, 2/5 at 0900 here at Quantico. Does
that work for you preliminarily?

Also,_ is now based in South A?icathe next 2 weeks. has also
transferred to Houston, but we can try to get him in.

I'm still trying to get the clearance info squared away.

0

Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Wednesday, January 23, 2013 4:49 PM
To:
Subject: Phone Call

are is my info.

Take care.
Tom

Page 1370 of 2169

02694

From: Fein, Ashden MAJ USARMY MDW (US)

To: Qaniel, Qharles ,1 9w USARMY ATEQ Hall, gassing olv Prajher, Jay
QIV LJSARMY HQDA (L15)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY -
USARMY HQDA DCS G-2 (US)



Subject: RE: security experts (UNCLASSIFIED)
Date: Monday, February 04, 2013 10:05:00 AM
Thank you.



From: CIV (US)

Sent: Monday, February 04, 2013 9:50 AM

To: Fein, Ashden MAJ USARMY MDW Ganiel, Charles CIV USARMY ATEC

Hall, Cassius CIV Prather, Jay CIV USARMY HQDA (US)

Cc: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY CIV

USARMY HQDA DCS G-2 (US)

Subject: RE: security experts (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

I have no one I can spare on short notice.

Army Research and Technology Protection Center
HQDA ODCS G2,





From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, February 04, 2013 9:44 AM

To: Ganiel, Charles CIV USARMY ATEC Hall, Cassius CIV

Prather, Jay CIV USARMY HQDA CIV (US)

Cc: Hurley, Thomas MAJ USARMY
Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY (US)

Subject: security experts

Importance: High

Gents,
As you know, the defense had meetings scheduled this morning at 0900 and

1100 at the Department of State, and Mr. Hall had to cancel for a medical

Page 1371 of2169

02695

issue and Mr. Ganiel, Mr. -, and Mr. Prather are not available based
on prior obligations. Do any of you know of anyone else who is a security
expert that could ?ll in at the last minute to assist? They would need to

be at the Department of State NLT 1050 for a 1100 meeting with AMB Kozak.
All parties are included on this email.

Thank you!

V/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1372 of 2169

02696

From: Ganiel, Charles CIV USARMY ATEC (US)

To: in A MA ARMY MDW Hall, gassius QIV Prther, Jay QIV LJSARMY HQDA
us

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY (US)

Subject: RE: security experts (UNCLASSIFIED)

Date: Monday, February 04, 2013 9:45:56 AM



Classi?cation: UNCLASSIFIED
Caveats: NONE

I don't know of any. Sorry.
Chuck



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, February 04, 2013 9:44 AM

To: Ganiel, Charles CIV USARMY ATEC Hall, Cassius CIV Prather, Jay CIV USARMY

HQDA cw

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY
(US)

Subject: security experts
Importance: High

Gents,
As you know, the defense had meetings scheduled this morning at 0900 and 1100 at the Department of State, and
Mr. Hall had to cancel for a medical issue and Mr. Ganiel, Mr. -, and Mr. Prather are not available based

on prior obligations. Do any of you know of anyone else who is a security expert that could ?ll in at the last minute
to assist? They would need to be at the Department of State NLT 1050 for a 1100 meeting with AMB Kozak.

All parties are included on this email.
Thank you!

v/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1373 of 2169

02697







From: Fein, Ashden MAJ USARMY MDW (US)

To: Lianiel, LEharles l1 LEIV L13ARMY Hall, gassius LEIV Prather, Jay LEIV L13ARMY HQDA
us

Cc: Hurley, Thomas MAJ USARMY Tooman Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY (US)

Bcc:
1&1; USARMY

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

Whyte, Hunter CPT USARMY (US)

Subject: security experts

Date: Monday, February 04, 2013 9:44:00 AM

I mportance: High

Gents,

As you know, the defense had meetings scheduled this morning at 0900 and 1100 at the Department of State, and
Mr. Hall had to cancel for a medical issue and Mr. Ganiel, Mr-, and Mr. Prather are not available based
on prior obligations. Do any of you know of anyone else who is a security expert that could ?ll in at the last minute
to assist? They would need to be at the Department of State NLT 1050 for a 1100 meeting with AMB Kozak.

All parties are included on this email.

Thank you!

V/r
MAJ Fein

Page 1374 of 2169

02698






From: Fein, Ashden MAJ USARMY MDW (US)
To: rl Th MA ARMY
Cc: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Overgaard, Angel CPT USARMY (US)
Bcc: LTCOL USMC
_lU_Sl; USARMY
Mitroka, Katherine CPT USARMY von Elten,
Alexander (Alec) CPT USARMY Whyte, Hunter CPT USARMY (US)
Subject: USMC POC info
Date: Monday, February 04, 2013 8:11:00 AM
Gents,

Good morning.

- The military defense counsel who would likely be interviewing
MajGen McKenzie is MAJ Tom Hurley (in the T0 line). The other defense
counsel are Mr. David Coombs and CPT Josh Tooman (CC line).

MAJ Hurley-_ is the new POC for MajGen McKenzie.

V/r
MAJ Fein

Page 1375 of 2169

02699



From: Fein, Ashden MAJ USARMY MDW (US)

To: rl Th MA ARMY
Subject: RE: Phone Call

Date: Friday, February 01, 2013 11:02:00 AM

Joe,

They both have TS clearances and are read-on; however no TS or SCI info should be discussed as per the
government and defense's notice.

v/r

Ashden



From:

Sent: Friday, February 01, 2013 10:58 AM
To: Hurley, Thomas MAJ USARMY (US)
Cc: Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: Phone Call

Tom-

Also, I need SSNs for both you and Mr. Hall for the visitor request paperwork. Do you both have IC badges? If
not, please pass TS clearances for both of you - it will make it easier for the visitor approval paperwork.

Thanks.



Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From:

Sent: Friday, February 01, 2013 10:55 AM

To: 'Hurley, Thomas MAJ OSD OMC Defense'
Cc: 'Fein, Ashden MAJ USARMY MDW
Subject: RE: Phone Call

Tom-

2/ 5 at 9am at Quantico it is. I need your security manager to pass clearances for you and Mr. Hall via JPAS utilizing
SMO Code FBIDC for up to TS, and FBIDC2 if SCI will be discussed ASAP. Have you been down here before?

Page 1376 of 2169

02700

We are on the FBI Academy complex at MCBQ, in the Engineering Research Facility. Here are directions:

1) I-95 to exit 148 (Russell Road, Marine Corps Base)

2) Turn right at end of ramp onto Russell Road

3) Continue on Russell Road until you hit gate for entry onto Marine Corps Base.

4) Russell Road, once you get past the gate, will change names to

5) Stay on MCB l. WATCH YOUR SPEED LIMIT - the Marine Corps Police are aggressive and unforgiving with
respect to speed limits. Remain on the main road. You will pass a ?re station on your left.

6) About 1400 feet after the ?re station, the main road (MCB 1) will change to MBC4 right after a clearing in the
woods on your left. Remain on MCB4. Shortly after the change ?om to MCB4 you will pass a
maintenance yard on your left, and a shooting range and water tower on your right.

7) Shortly after that, you will come up to the road leading to the East Gate to the FBI Complex. You will see FBI
signs on the road. Turn right to the east gate. Provide your ID to the FBI Police of?cers in the booth.

8) After you clear the booth, make your second left onto J. Edgar Hoover Road.

9) Take that to the 2nd left and turn into the driveway. You should see signs for the Engineering Research Facility.
10) Go through the gate and drive toward the front door of the building. There are visitor spots right in front of the
main door that you can park in. Go inside to security, and when you arrive, they will call me.



Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Wednesday, January 30, 2013 9:40 AM
To:
Subject: RE: Phone Call



It absolutely does work for me. I will be bringing with me (at least) Mr. Cassius Hall. He's our security expert and,
by order of the court, he's got to be there every time we talk about classi?ed stuff with a witness.

Sorry it took me so long to get back to you.

Tom



From: .

Sent: Friday, January 25, 2013 5:28 PM

To: Hurley, Thomas MAJ OSD OMC Defense
Subject: RE: Phone Call

Tom-

The way it's shaping up it looks like we'll need to set up the meeting for Tues, 2/5 at 0900 here at Quantico. Does

Page 1377 of 2169

02701

that work for you preliminarily?

Also,_ is now based in South A?icathe next 2 weeks. has also
transferred to Houston, but we can try to get him in.

I'm still trying to get the clearance info squared away.



Assistant General Counsel
Science Technology Law Unit
Federal Bureau of Investigation



Con?dentiality Statement: This message is transmitted to you by the Of?ce of the General Counsel of the Federal
Bureau of Investigation. The message, along with any attachments, may be con?dential and legally privileged. If
you are not the intended recipient of this message, please destroy it without further retention or
dissemination (unless otherwise required by law). Please notify the sender of the error by a separate e-mail or by

caning



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Wednesday, January 23, 2013 4:49 PM
To:
Subject: Phone Call

are is my info.

Take care.
Tom

Page 1378 of 2169

02702

From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ LJSARMY TQQman, aJoshua ,1 (PT LJSARMY
.05).

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

CPT USARMY von Elten Alexander (Alec) CPT USARMY USARMY (US)

Bcc:
Mitroka, Katherine

CPT USARMY (US)





Subject: RE: Witness Information
Date: Thursday, January 31, 2013 12:12:00 PM
David,

We submitted the requests for the security clearances and they are being processed. All three individuals provided
their information. We have not heard from Mr. - since the phone call.

v/r
Ashden



From: [m il rm i

Sent: Thursday, January 31, 2013 12:03 PM

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

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY v0n Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: Witness Information

Ashden,

I wanted to verify that you have received that you needed to process the interim security clearances for the Defense
witnesses.

Also, have you heard anything from Mr. - He is ignoring the emails and calls that I have left for him.

Best,
David

David E. Coombs

Law Of?ce 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 1379 of 2169

02703

From:

To: Hurley, Thomas MAJ LJSARMY ngman, Joshua ,1 QPT LJSARMY Fein, Ashden MAJ LJSARMY MDW


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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: Witness Information
Date: Thursday, January 31, 2013 12:03:29 PM



Ashden,

I wanted to verify that you have received that you needed to process the interim security clearances for the Defense
witnesses.

Also, have you heard anything from Mr. - He is ignoring the emails and calls that I have left for him.

Best,
David

David E. Coombs

Law Of?ce 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 1380 of 2169

02704

From:

To: r Th MA ARMY Tooman, Joshua ,1 QPT LJSARMY Fein, Ashden MAJ LJSARMY MDW
.05).

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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Discovery
Date: Wednesday, January 30, 2013 7:43:35 PM



Ashden,
Thank you for the clari?cation. I will be sending the new discovery to you tomorrow.

Best,
David

David E. Coombs

Law Of?ce 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


From: Fein, Ashden MAJ USARMY MDW (US)

Sent: January?30 j 2013

To: 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
- USARMY (US)

Subject: RE: Discovery

David,
Our address is:

Office of the Staff Judge Advocate
ATTN: MAJ Fein
JFHQ-NCR and US. Army Military District of Washington

Fort Lesley J. McNair, DC 20319-5058

As for the material we marked, that information cannot be produced for delivery to the defense. This is the material
that was and is available for inspection at the organizations. We just went out there to apply BATES numbers to
the same documents to ensure they are properly tracked today and in the future. They are still at the organizations
for inspection, throughout the entire trial.

v/r

Ashden



From: [m il rm i

Sent: Wednesday, January 30, 2013 5:52 PM

To: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Fein, Ashden MAJ

Page 1381 of2169

02705

USARMY MDW (US)

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

Subject: RE: Discovery

Ashden,

Thank you for tracking down this information for me. I appreciate the prompt response. When do you plan to send
the information discussed in #3 below?

I also have some additional reciprocal discovery production for you. In looking through our previous discovery
production, I noticed that some of the open source information for the diplomatic cables was improperly marked.
Instead of reproducing all of our previous discovery, I have simply given new BATES numbers to the cable open
source. The new BATES numbers are (024742 - 027968). What would be the best address for me to mail this to

you?

Best,
David

David E. Coombs

Law Of?ce of David E. Coombs

11 South Angell Street, #317
Providence, RI 02906

Toll Free: l-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282


From: Fein, Ashden MAJ USARMY MDW (US)

Sent: lJanuaryFB 2013

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
USARMY (US)

Subject: RE: Discovery

David,

1. BATES 00523673 - 00523683 and 00523699 - 00523702 were hand delivered to MAJ Hurley on 18 October
2012, and delivered via FEDEX (Tracking 7992 2437 8390) to the NWC on 19 October 2012.

2. As of last night, the United States produced discovery ends at BATES 00526366.
3. Over the past week, the prosecution BATES stamped all the remaining documents that have been made available
for inspection at the Department of State, ODNI, and OGA2, and their BATES #s are 00526367-527l2l. These are

the same documents the defense counsel have reviewed, but we went back to add BATES #s to ensure they are
accounted for in discovery.

4. The only information that has not been BATES stamped at this point is the Giglio Jencks material we have for
inspection, and we will work on having that stamped, and any new information we are working on producing.

v/r

Ashden



Page 1382 of 2169

02706

From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Tuesday, January 29, 2013 8:46 PM

To: Fein, Ashden MAJ USARMY MDW 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
USARMY (US)

Subject: Discovery

Ashden,
I would like to verify the following:

1) That the Government has not produced in discovery (BATES 00523673 -
00523683) and (BATES 00523699 - 00523702); and

2) The Government's produced discovery ends at BATES 00526366.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Page 1383 of 2169

02707

From: Fein, Ashden MAJ USARMY MDW (US)

To: Hurley, Thomas MAJ USARMY Tooman, Joshua ,1 QPT USARMY
.05).

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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Discovery
Date: Wednesday, January 30, 2013 6:21 :00 PM



David,
Our address is:

Office of the Staff Judge Advocate
ATTN: MAJ Fein
JFHQ-NCR and US. Army Military District of Washington

Fort Lesley J. McNair, DC 20319-5058

As for the material we marked, that information cannot be produced for delivery to the defense. This is the material
that was and is available for inspection at the organizations. We just went out there to apply BATES numbers to
the same documents to ensure they are properly tracked today and in the future. They are still at the organizations
for inspection, throughout the entire trial.

v/r

Ashden



From: [mailtozcoombs arm courtmartialdefense.com]

Sent: Wednesday, January 30, 2013 5:52 PM

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

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

Subject: RE: Discovery

Ashden,

Thank you for tracking down this information for me. I appreciate the prompt response. When do you plan to send
the information discussed in #3 below?

I also have some additional reciprocal discovery production for you. In looking through our previous discovery
production, I noticed that some of the open source information for the diplomatic cables was improperly marked.
Instead of reproducing all of our previous discovery, I have simply given new BATES numbers to the cable open
source. The new BATES numbers are (024742 - 027968). What would be the best address for me to mail this to
you?

Best,
David

David E. Coombs

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

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

Page 1384 of 2169

02708

Fax: (508) 689-9282


From: Fein, Ashden MAJ USARMY MDW (US)

Sent: lJanuaryFB 2013

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
- USARMY (US)

Subject: RE: Discovery

David,

1. BATES 00523673 - 00523683 and 00523699 - 00523702 were hand delivered to MAJ Hurley on 18 October
2012, and delivered via FEDEX (Tracking 7992 2437 8390) to the NWC on 19 October 2012.

2. As of last night, the United States produced discovery ends at BATES 00526366.

3. Over the past week, the prosecution BATES stamped all the remaining documents that have been made available
for inspection at the Department of State, ODNI, and OGA2, and their BATES #s are 00526367-527121. These are
the same documents the defense counsel have reviewed, but we went back to add BATES #s to ensure they are
accounted for in discovery.

4. The only information that has not been BATES stamped at this point is the Giglio encks material we have for
inspection, and we will work on having that stamped, and any new information we are working on producing.

v/r

Ashden



From: David Coombs [m il rm i
Sent: Tuesday, January 29, 2013 8:46 PM

To: Fein, Ashden MAJ USARMY MDW 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
USARMY (US)

Subject: Discovery

Ashden,
I would like to verify the following:

1) That the Government has not produced in discovery (BATES 00523673 -
00523683) and (BATES 00523699 - 00523702); and

2) The Government's produced discovery ends at BATES 00526366.

Best,
David

David E. Coombs, Esq.

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

Toll Free: l-800-588-4156

Page 1385 of 2169

02709

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Page 1386 of 2169

02710

From:

To: r Th MA ARMY Tooman, Joshua ,1 QPT LJSARMY Fein, Ashden MAJ LJSARMY MDW
.05).

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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Discovery
Date: Wednesday, January 30, 2013 5:52:28 PM



Ashden,

Thank you for tracking down this information for me. I appreciate the prompt response. When do you plan to send
the information discussed in #3 below?

I also have some additional reciprocal discovery production for you. In looking through our previous discovery
production, I noticed that some of the open source information for the diplomatic cables was improperly marked.
Instead of reproducing all of our previous discovery, I have simply given new BATES numbers to the cable open
source. The new BATES numbers are (024742 - 027968). What would be the best address for me to mail this to
you?

Best,
David

David E. Coombs

Law Of?ce 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


From: Fein, Ashden MAJ USARMY MDW (US)

Sent: lJanuaryFB 2013

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
- USARMY (US)

Subject: RE: Discovery

David,

1. BATES 00523673 - 00523683 and 00523699 - 00523702 were hand delivered to MAJ Hurley on 18 October
2012, and delivered via FEDEX (Tracking 7992 2437 8390) to the NWC on 19 October 2012.

2. As of last night, the United States produced discovery ends at BATES 00526366.
3. Over the past week, the prosecution BATES stamped all the remaining documents that have been made available
for inspection at the Department of State, ODNI, and OGA2, and their BATES #s are 00526367-527121. These are

the same documents the defense counsel have reviewed, but we went back to add BATES #s to ensure they are
accounted for in discovery.

4. The only information that has not been BATES stamped at this point is the Giglio encks material we have for
inspection, and we will work on having that stamped, and any new information we are working on producing.

v/r

Page 1387 of 2169

02711

Ashden



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Tuesday, January 29, 2013 8:46 PM

To: Fein, Ashden MAJ USARMY MDW 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
USARMY (US)

Subject: Discovery

Ashden,
I would like to verify the following:

1) That the Government has not produced in discovery (BATES 00523673 -
00523683) and (BATES 00523699 - 00523702); and

2) The Government's produced discovery ends at BATES 00526366.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Page 1388 of 2169

02712






From: Fein, Ashden MAJ USARMY MDW (US)

To: "David 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 USARMY (US)

Bcc:

Mitroka, Katherine

CPT USARMY (US)

Subject: RE: Discovery

Date: Wednesday, January 30, 2013 3:36:00 PM

David,

1. BATES 00523673 00523683 and 00523699 00523702 were hand delivered to MAJ Hurley on 18 October
2012, and delivered via FEDEX (Tracking 7992 2437 8390) to the NWC on 19 October 2012.

2. As of last night, the United States produced discovery ends at BATES 00526366.

3. Over the past week, the prosecution BATES stamped all the remaining documents that have been made available
for inspection at the Department of State, ODNI, and OGA2, and their BATES #s are 00526367-527121. These are
the same documents the defense counsel have reviewed, but we went back to add BATES #s to ensure they are
accounted for in discovery.

4. The only information that has not been BATES stamped at this point is the Giglio encks material we have for
inspection, and we will work on having that stamped, and any new information we are working on producing.

v/r

Ashden



From: David Coombs

Sent: Tuesday, January 29, 2013 8:46 PM

To: Fein, Ashden MAJ USARMY MDW 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
USARMY (US)

Subject: Discovery

Ashden,
I would like to verify the following:

1) That the Government has not produced in discovery (BATES 00523673 -
00523683) and (BATES 00523699 - 00523702); and

2) The Government's produced discovery ends at BATES 00526366.

Best,
David

David E. Coombs, Esq.

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

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

Page 1389 of 2169

02713

Fax: (508) 689-9282



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Page 1390 of 2169

02714

From: Tooman, Joshua CPT USARMY (US)
To: Fein, Ashden MAJ LJSARMY MDW r Th MA ARMY "David
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Witness Issues
Date: Wednesday, January 30, 2013 2:58:38 PM



Thanks, sir.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Tuesday, January 29, 2013 4:46 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
- USARMY (US)

Subject: RE: Witness Issues

Defense,

We did not hear back from you about the below list, except Josh added coordination issues with VADM Harward's
of?ce, and sent an email a few minutes ago asking for updates. Below are the updates:

Carr - classi?ed interview or not? Yes. The information is classi?ed]

- - 0900 on Thursday, 24 Jan 13 Meeting occurred. We are tracking that he either
luntarily ?lls out a declaration or we will work with defense on a stipulation of expected testimony]

MajGen McKenzie - need updated contact info It is our understanding that your email went through
and the USMC OTJAG (equivalent) is coordinating to setup the interview]

a - con?ised about her authentication testimony She should not be con?ised any longer]

- need updated contact info His contact information is accurate and he has moved to
Houston]

- -s - have not returned calls Your contact with the attorneys at the FBI will
assist you setting up interviews with each of these witnesses. It is our understanding that the FBI HQ CART
attorneys are assisting you and will continue]

Mr. Travieso - need updated contact info Contact information provided is current. We con?rmed by
calling the same number]

LT Hoskins - need updated contact info LT Hoskins is not on active duty any longer and can be

reached at

VADM Harward - need assistance with locking down a ?rm date We are working with the OSJA and
his front of?ce. I recommend locking in the date with all the other witnesses so there are no delays. Then you can
separately lock down VADM Harward, especially because he travels and could be in the NCR between now and
then. More to follow on locking down the date.]

v/r
MAJ Fein



Page 1391 of2169

02715

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 10:50 AM

To: 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
USARMY (US)

Subject: Witness Issues

Importance: High

Defense,
I am tracking the below witness administrative issues. Please con?rm so we can get them all resolved ASAP:

Carr - classi?ed interview or not?
a - - 0900 on Thursday, 24 Jan 13
jGen McKenzie - need updated contact info
- confused about her authentication testimony
- need updated contact info
- have not returned calls
eed updated contact info

LT Hoskins - need updated contact info





Are there any others as of today?
Thank you!

v/r
MAJ Fein

Page 1392 of 2169

02716



From: Fein, Ashden MAJ USARMY MDW (US)
To: Hurley, Thomas MAJ LJSARMY TQQman, Joshua ,1 QPT LJSARMY
.05).
Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Bcc:
CPT USARMY (US)
Subject: Re: Discovery
Date: Tuesday, January 29, 2013 9:29:48 PM



David. I will be able to confirm tomorrow.

Vr
Ashden

Original Message

From: David Coombs [m il rm i

Sent: Wednesday, January 30, 2013 01:46 AM

To: Fein, Ashden MAJ USARMY MDW 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
- USARMY (US)

Subject: Discovery

Ashden,
I would like to verify the following:

1) That the Government has not produced in discovery (BATES 00523673 -
00523683) and (BATES 00523699 - 00523702); and

2) The Government's produced discovery ends at BATES 00526366.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1393 of 2169

02717

Page 1394 of 2169

02718

From: David Coombs

To: Fein, Ashden MAJ LJSARMY MDW Hurley, Thomas MAJ LJSARMY ngman, Joshua ,1 QPT LJSARMY
.05).

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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)

Subject: Discovery
Date: Tuesday, January 29, 2013 8:46:16 PM



Ashden,
I would like to verify the following:

1) That the Government has not produced in discovery (BATES 00523673 -
00523683) and (BATES 00523699 - 00523702); and

2) The Government's produced discovery ends at BATES 00526366.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1395 of 2169

02719

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

CPT USARMY von Elten Alexander (Alec) CPT USARMY USARMY (US)






Bcc:
Mitroka Katherine
CPT USARMY (US)
Subject: RE: Witness Issues
Date: Tuesday, January 29, 2013 4:46:00 PM
Defense,

We did not hear back from you about the below list, except Josh added coordination issues with VADM Harward's
of?ce, and sent an email a few minutes ago asking for updates. Below are the updates:

Carr - classi?ed interview or not? Yes. The information is classi?ed]

- - 0900 on Thursday, 24 Jan 13 Meeting occurred. We are tracking that he either
luntarily ?lls out a declaration or we will work with defense on a stipulation of expected testimony]

MajGen McKenzie - need updated contact info It is our understanding that your email went through
and the USMC OTJAG (equivalent) is coordinating to setup the interview]

a - con?ised about her authentication testimony She should not be con?ised any longer]

- need updated contact info His contact information is accurate and he has moved to

uston]

- - have not returned calls Your contact with the attorneys at the FBI will
assist you setting up interviews with each of these witnesses. It is our understanding that the FBI HQ CART
attorneys are assisting you and will continue.]

Mr. Travieso - need updated contact info Contact information provided is current. We con?rmed by
calling the same number]

LT Hoskins - need updated contact info LT Hoskins is not on active duty any longer and can be

reached at

VADM Harward - need assistance with locking down a ?rm date We are working with the OSJA and
his front of?ce. I recommend locking in the date with all the other witnesses so there are no delays. Then you can
separately lock down VADM Harward, especially because he travels and could be in the NCR between now and
then. More to follow on locking down the date.]

v/r
MAJ Fein



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 10:50 AM

To: 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
USARMY (US)

Subject: Witness Issues

Page 1396 of 2169

02720

Importance: High
Defense,
I am tracking the below witness administrative issues. Please con?rm so we can get them all resolved ASAP:

Carr - classi?ed interview or not?

- - 0900 on Thursday, 24 Jan 13

jGen McKenzie - need updated contact info

- confused about her authentication testimony
- need updated contact info
- have not returned calls
Mr. Travi(es eed updated contact info
LT Hoski?s - need updated contact info



Are there any others as of today?







Thank you!

v/r
MAJ Fein

Page 1397 of 2169

02721





From: Fein, Ashden MAJ USARMY MDW (US)

To: PT ARMY

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY "David Coombs"; Hurley, Thomas MAJ
USARMY (US)

Bee:
USARMY

Mitroka, Katherine CPT USARMY (US)

Subject: RE: CENTCOM

Date: Tuesday, January 29, 2013 4:22:00 PM

Josh,

I will reply in a moment to my previous emails about this. Thanks!

V/r

MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Tuesday, January 29, 2013 4:22 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY 'David Coombs'; Hurley,
Thomas MAJ USARMY (US)

Subject: CENTCOM

Sir

Do you have any update on our attempts to schedule interviews with the CENTCOM witnesses?

Thanks,

Josh

Page 1398 of 2169

02722



From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY "David Coombs"; Hurley, Thomas MAJ
USARMY (US)

Subject: CENTCOM

Date: Tuesday, January 29, 2013 4:21 :43 PM

Sir

Do you have any update on our attempts to schedule interviews with the CENTCOM witnesses?

Thanks,

Josh

Page 1399 of 2169

02723

From: Tooman, Joshua CPT USARMY (US)

To: USARMY USAMDW (US)

Cc: Ashden MAJ USARMY MDW US USARMY USAMDW Hurley Thomas MAJ


Subject: RE: Question about equipment (UNCLASSIFIED)

Date: Tuesday, January 29, 2013 3:02:41 PM



RE

We spoke to 5 about the Dongles earlier today. We have them and I believe that MAJ Hurley sent Chief a
picture ofth .

Thanks,
CPT

From: USARMY USAMDW (US)

Sent: Tuesday, January 29, 2013 1:38 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Tooman,
Good afternoon, Sir. I was wondering if you were able to make any headway
with the Mount Image Pro Dongles? I am trying to clean up the hand receipt

and any assistance you can provide would be greatly appreciated.

Thank you, Sir, and have a nice day.





Paralegal NCO
JFHQ-NCR, MDW



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 4:07 PM

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

Thanks; we'll take a look.



From: USARMY USAMDW (US)
Sent: Wednesday, January 23, 2013 4:05 PM

To: Tooman, Joshua CPT USARMY (US)

Subject: RE: Question about equipment (UNCLASSIFIED)

Page 1400 of 2169

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Tooman,

A Mount Image Dongle looks like a very small (about 1 inch long) USB stick
on a nylon lanyard. The USB connector is a Mini-B type. They should have a
rubber cap and sleeve on them, making them each about l"xl/4"xl/4"
rectangular sticks.

I have attached a picture in case I am over-describing it.

Thank you, Sir.



Paralegal NCO
JFHQ-NCR, MDW



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 3:52 PM

To: USARMY USAMDW (US)
Subject: RE: Question about equipment (UNCLASSIFIED)

MP

What is a Mount Image Dongle?

Thanks,

CPT



From: USARMY USAMDW (US)

Sent: Wednesday, January 23, 2013 10:17 AM

To: Tooman, Joshua CPT USARMY (US)

Cc: Fein, Ashden MAJ USARMY MDW USARMY USAMDW
(US)

Subject: Question about equipment (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Good morning, Sir,

Page 1401 of2169

02724

In an attempt to alleviate any possible confusion, I am a Paralegal NCO
working for MAJ Fein.

I am emailing you in regards to a pair of Dongles that TDS has signed for

from us. MAJ Kemkes originally signed for them, and told me that
you may have taken all of the equipment with you Whe brought onto
the case.

If you could verify that you are in possession of the Mount Image Dongles,
and their numbers (M06, M08), I would greatly appreciate it.

Thank you, Sir.


Paralegal NCO

JFHQ-NCR, MDW

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1402 of 2169

02725

02726



From: David Coombs

To: USARMY MCCOE (US): Fein, Ashden LJSARMY MDW TQQman, ,tgghua ,1 QPT
LJSARMY (US)

Cc: Hurley, Thomas MAJ USARMY Overgaard, Angel CPT USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
us ;??c_iusmwusxwow us

Subject: Declaration
Date: Tuesday, January 29, 2013 1:23:28 PM
I mportance: High



Can you please let us know if you have any issues with the revised

declaration? If you do not, could you please sign it and return it to the
Government and myself today?

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1403 of 2169

02727





From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW

Cc: Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter
CPT USARMY von Elten, Alexander (Alec) CPT USARMY "David Coombs";
USARMY Hurley, Thomas MAJ USARMY Hall, Cassius CIV Ganiel Charles CIV USARMY
ATEC Smith, Lillian CIV USARMY HQDA EM (US)

Subject: Digital Evidence

Date: Monday, January 28, 2013 8:42:36 AM

Sir

As you know, our forensics experts are coming in this week. If you all have any more digital evidence for us I can
swing by McNair this morning and pick it up.

Thanks,

Josh

Page 1404 of 2169

02728

From: Fein Ashden MAJ USARMY MDW (US)
To: WM PT ARMY USAMDW us
Cc: Hurlev. Thomas MAJ USARMY (US):



Morrow. JoDean (Joe) CPT USARMY USAMDW (US): Overoaard. Anoel CPT USARMY (US)



Bcc:

CPT USARMY (US)
Subject: Re: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)
Date: Saturday, January 26, 2013 12:37:39 PM



I estimate no more than 1 hour.

From: Tooman, Joshua CPT USARMY (US)

Sent: Saturday, January 26, 2013 05:20 PM

To: USARMY USAMDW Fein, Ashden MAJ USARMY MDW (US)

Cc: Trent Struttmann 'David Coombs'
Hurley, Thomas MAJ USARMY (US)

Subject: RE: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)

I



Understood. The plan has changed, and we will need to change the ?ight. At a minimum, Trent will be performing
forensics for us on Friday.

MAJ Fein, do you have an estimate on how long the forensics will take on the UBL stuff? Can it be completed in a
day or should we plan on being there Saturday, as well?

Thanks,

CPT



From: USARMY USAMDW (US)

Sent: Saturday, January 26, 2013 12:02 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: Re: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)

Sir,

We could work the schedule ?ight but as you recall those were the time frames your expert requested. If he wants
them changed please let me know and we will work towards it.



Page 1405 of 2169

02729



"Sent from my BlackBerry"

From: Tooman, Joshua CPT USARMY (US)

Sent: Saturday, January 26, 2013 03:31 PM

To: USARMY ts@cyberagentsinc.com
Cc: USARMY USAMDW (US)

Subject: RE: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)



Thank you, a

Chief/Tren --Presently, we are scheduled to run forensics on evidence requiring Mr. Prather's presence on Friday. I
imagine this will be dif?cult with Trent's early ?ight. Will it be possible to move that ?ight back? Does that work
with your schedule, Trent?



CPT Tooman



From: USARMY (US)

Sent: Friday, January 25, 2013 9:01 AM

To: ts@cyberagentsinc.com

Cc: USARMY USAMDW Tooman, Joshua CPT USARMY (US)
Subject: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr. Struttmann,

Attached is your travel itinerary for 28 Jan 1 Feb. Please let me know if you have any questions or concerns.

Page 1406 of 2169

02730



MP

OSJA, MDW

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1407 of 2169

02731



From: Tooman, Joshua CPT USARMY (US)

To: USARMY USAMDW in A MA ARMY MDW
Cc: Trent Struttmann; "David Coombs"; Hurley, Thomas MAJ USARMY (US)
Subject: RE: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)

Date: Saturday, January 26, 2013 12:20:04 PM

(6



Understood. The plan has changed, and we will need to change the ?ight. At a minimum, Trent will be performing
forensics for us on Friday.

MAJ Fein, do you have an estimate on how long the forensics will take on the UBL stuff? Can it be completed in a
day or should we plan on being there Saturday, as well?

Thanks,

CPT



From: USARMY USAMDW (US)

Sent: Saturday, January 26, 2013 12:02 PM

To: Tooman, Joshua CPT USARMY Fein, Ashden MAJ USARMY MDW (US)
Subject: Re: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)

Sir,

We could work the schedule ?ight but as you recall those were the time frames your expert requested. If he wants
them changed please let me know and we will work towards it.







"Sent from my BlackBerry"

From: Tooman, Joshua CPT USARMY (US)
Sent: Saturday, January 26, 2013 03:31 PM

To: USARMY ts@cyberagentsinc.c0m

Page 1408 of 2169

02732

Cc: USARMY USAMDW (US)
Subject: RE: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)

Thank you, a

Chief/Trent--Presently, we are scheduled to run forensics on evidence requiring Mr. Prather's presence on Friday. I
imagine this will be dif?cult with Trent's early ?ight. Will it be possible to move that ?ight back? Does that work
with your schedule, Trent?



CPT Tooman



From: USARMY (US)

Sent: Friday, January 25, 2013 9:01 AM

To: ts@cyberagentsinc.com

Cc: USARMY USAMDW Tooman, Joshua CPT USARMY (US)
Subject: Travel Itinerary for 28 Jan - 1 Feb (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr. Struttmann,

Attached is your travel itinerary for 28 Jan 1 Feb. Please let me know if you have any questions or concerns.



RR

OSJA, MDW

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1409 of 2169

02733

Page 1410 of2169

02734



From: Fein, Ashden MAJ USARMY MDW (US)

To: Tooman, aJoshua ,1 (PT LJSARMY Hurley, Thomas MAJ LJSARMY
4L5).

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

Bcc:
CPT USARMY (US)

Subject: Re: Witness Issues

Date: Saturday, January 26, 2013 11:51 :18 AM



Josh. I will start coord with centcom on monday. We never heard back ?om yall on our list you are referencing. Is
that list of witness commo issues accurate?

From: Tooman, Joshua CPT USARMY (US)

Sent: Saturday, January 26, 2013 04:43 PM

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

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

Subject: RE: Witness Issues

Sir

In addition, we are having a hard time getting a ?rm date with VADM Harward. We've been given a range of 12-14
FEB, but I have been unable to get a date con?rmed with his POC. Obviously, he has the tightest schedule of the
CENTCOM folks and is the linchpin for us getting all the other folks down there scheduled. So far the others are
available (excepting LT Hoskins and Mr. Travieso, with whom we have not spoken and which you are tracking),
but I am concerned that their schedules will start to ?ll up.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 10:51 AM

To: 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
USARMY (US)

Subject: Witness Issues

Defense,

Page 1411 of2169

02735

I am tracking the below witness administrative issues. Please con?rm so we can get them all resolved ASAP:

Carr - classi?ed interview or not?

- - 0900 on Thursday, 24 Jan 13

jGen McKenzie - need updated contact info

- confused about her authentication testimony
- need updated contact info
- have not returned calls
. Travies need updated contact info
LT Hoskins - need updated contact info








Are there any others as of today?
Thank you!

v/r
MAJ Fein

Page 1412 of2169

02736

From: Tooman, Joshua CPT USARMY (US)

To: Fein, Ashden MAJ LJSARMY MDW Hurley, Thomas MAJ LJSARMY


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

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Witness Issues
Date: Saturday, January 26, 2013 11:43:19 AM



Sir

In addition, we are having a hard time getting a ?rm date with VADM Harward. We've been given a range of 12-14
FEB, but I have been unable to get a date con?rmed with his POC. Obviously, he has the tightest schedule of the
CENTCOM folks and is the linchpin for us getting all the other folks down there scheduled. So far the others are
available (excepting LT Hoskins and Mr. Travieso, with whom we have not spoken and which you are tracking),
but I am concerned that their schedules will start to ?ll up.

Thanks,

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 10:51 AM

To: 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
USARMY (US)

Subject: Witness Issues

Defense,
I am tracking the below witness administrative issues. Please con?rm so we can get them all resolved ASAP:

Carr - classi?ed interview or not?
a - 0900 on Thursday, 24 Jan 13
ajGen McKenzie - need updated contact info
- COl?lquCd about her authentication testimony
- need updated contact info
- have not returned calls
. Travies need updated contact info
LT Hoskins - need updated contact info





Are there any others as of today?
Thank you!

v/r
MAJ Fein

Page 1413of2169

02737

Page 1414 of2169

02738

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

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
us ;??c_xusmwusxwow us



Subject: RE: Teleconference Scheduled (UNCLASSIFIED)
Date: Friday, January 25, 2013 9:44:17 AM
Ashden,

I have removed!. - from the email chain. I would not have sent an
email that gave im the option of not signing a declaration.

(6)
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Friday, January 25, 2013 9:41 AM

To: David Coombs;_ CIV USARMY MCCOE Tooman, Joshua
CPT USARMY (US)

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

USARMY USARMY USAMDW (US)

Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Mr. Coombs,
If - is not willing to sign a declaration, then the prosecution
is tanding by to enter into a stipulation of expected testimony that is

agl?eable to both parties, as we all discussed on the record with the Court.

v/r
MAJ Fein


From: David Coombs [mailtozcoombs arm courtmartialdefense.com]
Sent: Friday, January 25, 2013 9:32 AM

Page 1415 of2169

02739

To: CIV USARMY MCCOE Fein, Ashden MAJ USARMY MDW
Tooman, Joshua CPT USARMY (US)

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

USARMY USARMY USAMDW (US)

Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

(gave you had an opportunity to review the amended declaration? If so, do
you believe we need to schedule another teleconference? If not, please sign

the declaration, scan it, and email it to the Government and myself. Please
let me know if you have any questions.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: David Coombs com]
Sent: Thursday, January 24, 2013 10:06 AM
To: CIV USARMY MCCOE 'Fein, Ashden MAJ USARMY MDW
'Tooman, Joshua CPT USARMY
Cc: 'Hurley, Thomas MAJ USARMY 'Overgaard, Angel CPT USARMY
'Morrow, JoDean (Joe) CPT USARMY USAMDW 'Whyte, Hunter
CPT USARMY 'von Elten, Alexander (Alec) CPT USARMY 3
USARMY USARMY USA
Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

I have made the requested changes to your declaration. If you identify any
additional substantive changes that are needed, please let the Government

and myself know so that we can set up another conference call.

Best,
David

David E. Coombs, Esq.

Page 1416 of2169

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From:




CIV USARMY MCCOE (US)

Sent: Wednesday, January 23, 2013 11:23 AM

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

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

USARMY USARMY USAMDW (US)

Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Got it.

Regards,




From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:11 AM

To: CIV USARMY MCCOE
Tooman, Joshua CPT USARMY (US)

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

USARMY USARMY USAMDW (US)

Subject: Teleconference Scheduled

Importance: High

- Mr. Coombs, CPT Tooman,

A teleconference bridge is reserved starting tomorrow, 24 January 2013, at
0900 and ending at 1000. The dial-in instructions are:

Page 1417 of2169

02740

02741

Note: When you dial, you will be asked to input this PASSCODE:
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

V/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1418 of2169

02742



From: Fein, Ashden MAJ USARMY MDW (US)
To: CIV USARMY MCCOE (US): PT ARMY
Cc: Hurley, Thomas MAJ USARMY Overgaard, Angel CPT USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
us ;??c_xusmwuswow us



Bcc:
MDW CIV MitrokaI Katherine CPT USARMY (US)
Subject: RE: Teleconference Scheduled (UNCLASSIFIED)
Date: Friday, January 25, 2013 9:41 :00 AM
Mr. Coombs,

Ify. - is not willing to sign a declaration, then the prosecution is standing by to enter into a stipulation of
pected testimony that is agreeable to both parties, as we all discussed on the record with the Court.
(6)

v/r
MAJ Fein



From: David Coombs com]

Sent: Friday, January 25, 2013 9:32 AM

To: CIV USARMY MCCOE Fein, Ashden MAJ USARMY MDW Tooman,
Joshua CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Overgaard, Angel CPT USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT
USARMY USARMY USARMY USAMDW (US)
Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Mr.-

Have you had an opportunity to review the amended declaration? If so, do
you believe we need to schedule another teleconference? If not, please sign
the declaration, scan it, and email it to the Government and myself. Please
let me know if you have any questions.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1419 of2169

02743


From: David Coombs [m il rm i
Sent: Thursday, January 24, 2013 10:06 AM
To: CIV USARMY MCCOE 'Fein, Ashden MAJ USARMY MDW
'Tooman, Joshua CPT USARMY
Cc: 'Hurley, Thomas MAJ USARMY 'Overgaard, Angel CPT USARMY
'Morrow, JoDean (Joe) CPT USARMY USAMDW 'Whyte, Hunter
CPT USARMY 'von Elten, Alexander (Alec) CPT USARMY
USARMY USARMY USA
Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Mr.-

I have made the requested changes to your declaration. If you identify any
additional substantive changes that are needed, please let the Government
and myself know so that we can set up another conference call.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From:




CIV USARMY MCCOE (US)

Sent: Wednesday, January 23, 2013 11:23 AM

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

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

USARMY USARMY USAMDW (US)

Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Got it.
Regards,

Page 1420 of 2169



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:11 AM

To: CIV USARMY MCCOE
Tooman, Joshua CPT USARMY (US)

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

USARMY USARMY USAMDW (US)

Subject: Teleconference Scheduled

Importance: High

- Mr. Coombs, CPT Tooman,

A teleconference bridge is reserved starting tomorrow, 24 January 2013, at
0900 and ending at 1000. The dial-in instructions are:

Note: When you dial, you will be asked to input this PASSCODE:
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

V/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1421 of2169

02744

02745



From: David Coombs

To: CIV USARMY MCCOE (US): Fein, Ashden MAJ USARMY MDW TQQman, ,(gghua QPT
USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Overgaard, Angel CPT USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
us ;??c_xusmwusxwow us
Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Date: Friday, January 25, 2013 9:31 :45 AM



Have you had an opportunity to review the amended declaration? If so, do
you believe we need to schedule another teleconference? If not, please sign

the declaration, scan it, and email it to the Government and myself. Please
let me know if you have any questions.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: David Coombs [m il rm i
Sent: Thursday, January 24, 2013 10:06 AM
To: CIV USARMY MCCOE 'Fein, Ashden MAJ USARMY MDW
'Tooman, Joshua CPT USARMY
Cc: 'Hurley, Thomas MAJ USARMY 'Overgaard, Angel CPT USARMY
'Morrow, JoDean (Joe) CPT USARMY USAMDW 'Whyte, Hunter
CPT USARMY 'von Elten, Alexander (Alec) CPT USARMY 3
USARMY USARMY USA
Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

I have made the requested changes to your declaration. If you identify any

additional substantive changes that are needed, please let the Government
and myself know so that we can set up another conference call.

Best,
David

Page 1422 of 2169

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From:




CIV USARMY MCCOE (US)

Sent: Wednesday, January 23, 2013 11:23 AM

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

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

USARMY USARMY USAMDW (US)

Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Got it.

Regards,




From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:11 AM

To: CIV USARMY MCCOE
Tooman, Joshua CPT USARMY (US)

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

USARMY USARMY USAMDW (US)

Subject: Teleconference Scheduled

Importance: High

- Mr. Coombs, CPT Tooman,

A teleconference bridge is reserved starting tomorrow, 24 January 2013, at
0900 and ending at 1000. The dial-in instructions are:

Page 1423 of 2169

02746

02747



Note: When you dial, you will be asked to input this PASSCODE:
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

V/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1424 of 2169

02748

From: ToomanI Joshua CPT USARMY (US)
To: Pralhgr, l)ay QIV LJSARMY HQDA in A MA ARMY MDW i IV

CIV r Th MA ARMY Qanigl, Qharlgs l) QIV LJSARMY ATEQ
Smith, Lillian ?2 QIV LJSARMY HQDA ITA EM (LJS)





Cc: David Coombs Trent Struttmann;? USARMY
USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

Date: Friday, January 25, 2013 6:57:59 AM

Gentlemen

It seems to me that 1 FEB will work, if a SCIF can be secured. If need be we could work into Saturday.

Trent/ Security Experts, do you see any issue with that course of action?

Thanks,

Josh



From: Prather, Jay CIV USARMY HQDA (US)

Sent: Thursday, January 24, 2013 5:59 PM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Hall, Cassius CIV
CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV USARMY ATEC

Smith, Lillian CIV USARMY HQDA ITA EM (US)

Cc: David Coombs Trent Struttmann;

USARMY USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

I am avail on the 28th next will also be avail the 1st of Feb onward ..to include the weekend if need
we think this will take more than a day?

V/r

Jay R. Prather



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 5:06 PM

To: Tooman, Joshua CPT USARMY Hall, Cassius CIV CIV Hurley,
Thomas MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV USARMY
HQDA Smith, Lillian CIV USARMY HQDA ITA EM (US)

Page 1425 of 2169

02749

Cc: David Coombs Trent Struttmann;
USARMY USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

Also - Mr. Prather are you available over the weekend or at the beginning of
the following week?



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, January 24, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV

CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV
USARMY ATEC Prather, Jay CIV USARMY HQDA Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Cc: David Coombs Trent Struttmann;
USARMY USAMDW (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Sir

I am available over the weekend. The following Monday we have interviews in
the morning at the Department of State, but am available in the afternoon.

Trent, are you able to stay through knock this out over the weekend or at
the beginning of the following week?

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 1:58 PM

To: Hall, Cassius CIV CIV Hurley, Thomas

MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV
USARMY HQDA Tooman, Joshua CPT USARMY Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Gents,

At this point with such short notice we can get the infrastructure set for
the end of the week, but I do not think Mr. Prather is available the second
half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel,
Charles CIV USARMY ATEC Prather, Jay CIV USARMY HQDA Fein,
Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Smith, Lillian

Page 1426 of 2169

02750

CIV USARMY HQDA ITA EM (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts
(SME), to support next week visit for the forensics. If they are unable to
provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support
for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw (us)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

-,

Jay was aware of their visit, but I will contact CPT Tooman and see if we
can schedule another time.



From: CIV (US)

Sent: Thursday, January 24, 2013 1:00 PM

To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM Prather, Jay CIV USARMY HQDA (US)

Subject: RE: next week (UNCLASSIFIED)

Page 1427 of 2169

02751

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw am

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

-,

This is the week they were schedule to come. If your team cannot provide
someone, recommend we cancel, but they may already have their transportation
scheduled.



From: CIV (US)

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay
CIV USARMY HQDA (US)

cc=? USAM (usx? USAM

(US)
Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Page 1428 of 2169

02752

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records
in City Monday.

What day/time are you looking at. Understand your still coordinating but
those 2 events above are non-?exible.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23, 2013 15:24
To: Hall, Cassius CIV Prather, Jay USARMY HQDA -

CIV (US)
Cc: USARMY USAMDW USARMY

(US)
Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the
Classi?cation: UNCLASSIFIED

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1429 of 2169

02753

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1430 of 2169

02754

From: PratherI Jay CIV USARMY HQDA (US)
To: Fain, Ashden LJSARMY MDW PT ARMY Hall, Qa??iu? QIV

CIV rl Th MA ARMY Qanigl, Qharlgs QIV LJSARMY ATEQ
Smith, Lillian ?2 QIV LJSARMY HQDA EM (LJS)



Cc: David Coombs Trent Struttmann;? USARMY
USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

Date: Thursday, January 24, 2013 5:59:45 PM



I am avail on the 28th next will also be avail the of Feb onward ..to include the weekend if need
we think this will take more than a day?

V/r

Jay R. Prather



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 5:06 PM

To: Tooman, Joshua CPT USARMY Hall, Cassius CIV CIV Hurley,
Thomas MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV USARMY
HQDA Smith, Lillian CIV USARMY HQDA ITA EM (US)

Cc: David Coombs Trent Struttmann;
USARMY USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

Also - Mr. Prather are you available over the weekend or at the beginning of
the following week?



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, January 24, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius -
CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV

USARMY ATEC Prather, Jay CIV USARMY HQDA Smith, Lillian CIV

USARMY HQDA ITA EM (US)

Cc: David Coombs Trent Struttmann;

USARMY USAMDW (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Sir

I am available over the weekend. The following Monday we have interviews in
the morning at the Department of State, but am available in the afternoon.

Trent, are you able to stay through knock this out over the weekend or at
the beginning of the following week?

Page 1431 of2169

02755

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 1:58 PM

To: Hall, Cassius CIV CIV Hurley, Thomas

MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV
USARMY HQDA Tooman, Joshua CPT USARMY Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Gents,

At this point with such short notice we can get the infrastructure set for
the end of the week, but I do not think Mr. Prather is available the second
half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel,
Charles CIV USARMY ATEC Prather, Jay CIV USARMY HQDA Fein,
Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Smith, Lillian
CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts
(SME), to support next week visit for the forensics. If they are unable to
provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support
for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your #7

Page 1432 of 2169

02756



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw am
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we
can schedule another time.



From: CIV (US)

Sent: Thursday, January 24, 2013 1:00 PM

To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM Prather, Jay CIV USARMY HQDA (US)

Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..



From: Hall, Cassius CIV (US)
Sent: Thursday, January 24, 2013 12:56

Tor?mam

Page 1433 of 2169

02757

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

-,

This is the week they were schedule to come. If your team cannot provide
someone, recommend we cancel, but they may already have their transportation
scheduled.



From: CIV (US)

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay
CIV USARMY HQDA (US)

cc=? USARMY USAMDW wsx? USARMY

(US)
Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records
in City Monday.

What day/time are you looking at. Understand your still coordinating but
those 2 events above are non-?exible.

Page 1434 of 2169

02758



From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23; 2013 15:24
To: Hall; Cassius CIV Prather; Jay CIV USARMY HQDA -

CIV (US)
USARMY USAMDW USARMY







Cc:
(US)
Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the
Classi?cation: UNCLASSIFIED

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1435 of 2169

02759



From: Trent Struttmann
To: Tooman, Joshua ,1 QPT USARMY in A MA ARMY MDW Hall, ?2a??iu? QIV
CIV rl Th MA ARMY hi I rl IV ARMY ATE

Pr IV ARMY DA Smith, Lillian g; QIV USARMY HQDA ITA EM (L13)

Cc: "David Coombs"; USARMY USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

Date: Thursday, January 24, 2013 5:26:36 PM

Josh,

This date may have been moved due to a Judges conference, I am waiting on a
response from the attorney.

Trent

Trent Struttmann

Cyber Agents, Inc.

616 Pasadena Dr
Lexington, KY 40503
Office: +1 859 523 9081
Mobile: +1 859 368 2040




From: Trent Struttmann [mailtozts bera entsinc.com]
Sent: Thursday, January 24, 2013 5:14 PM
To: 'Tooman, Joshua CPT USARMY 'Fein, Ashden MAJ USARMY MDW
'Hall, Cassius CIV CIV 'Hurley, Thomas
MAJ USARMY 'Ganiel, Charles CIV USARMY ATEC 'Prather, Jay
CIV USARMY HQDA 'Smith, Lillian CIV USARMY HQDA ITA EM
Cc: 'DaVid Coombs
USARMY USAMDW
Subject: RE: next week (UNCLASSIFIED)

Josh,

I have US Brown at Fort Campbell starting Monday 4 February, and I'll need
to be there at least one day early to brief the attorney. I don't know that

even if I had a few hours on Saturday I could get done what I need to do.

Trent

Trent Struttmann

Cyber Agents, Inc.

616 Pasadena Dr
Lexington, KY 40503
Office: +1 859 523 9081
Mobile: +1 859 368 2040
in


From: Tooman, Joshua CPT USARMY
Sent: Thursday, January 24, 2013 4:43 PM
To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV

CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV
USARMY ATEC Prather, Jay CIV USARMY HQDA Smith, Lillian CIV

Page 1436 of 2169

02760

USARMY HQDA ITA EM (US)

Cc: David Coombs Trent Struttrnann;
USARMY USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Sir

I am available over the weekend. The following Monday we have interviews in
the morning at the Department of State, but am available in the afternoon.

Trent, are you able to stay through knock this out over the weekend or at
the beginning of the following week?

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 1:58 PM

To: Hall, Cassius CIV CIV Hurley, Thomas

MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV
USARMY HQDA Tooman, Joshua CPT USARMY Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Gents,

At this point with such short notice we can get the infrastructure set for
the end of the week, but I do not think Mr. Prather is available the second
half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel,
Charles CIV USARMY ATEC Prather, Jay CIV USARMY HQDA Fein,
Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Smith, Lillian
CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts
(SME), to support next week visit for the forensics. If they are unable to
provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support
for the forensic piece.

Page 1437 of 2169

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw am
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we

can schedule another time.



From: CIV (US)
Sent: Thursday, January 24, 2013 1:00 PM
To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM Prather, Jay CIV USARMY HQDA (US)

Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..

Page 1438 of 2169

02761



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

This is the week they were schedule to come. If your team cannot provide
someone, recommend we cancel, but they may already have their transportation
scheduled.



From: CIV (US)

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay
CIV USARMY HQDA (US)

cc=? USARMY USAMDW (usx? USARMY

(US)
Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records
in City Monday.

What day/time are you looking at. Understand your still coordinating but

Page 1439 of 2169

02762

02763

those 2 events above are non-?exible.



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 15:24

To: Hall, Cassius CIV Prather, Jay CIV USARMY HQDA -
CIV (US)

USAM (usx? USAM

(US)
Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the
Classi?cation: UNCLASSIFIED

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1440 of 2169

02764



From: Trent Struttmann
To: Tooman, Joshua ,1 (PT LJSARMY in A MA ARMY MDW Hall, Qa??iu? QIV
CIV r Th MA ARMY hi I r IV ARMY ATE

Pr IV ARMY DA Smith, Lillian ?2 QIV LJSARMY HQDA EM (L15)

Cc: "David Coombs"; USARMY USAMDW (US)

Subject: RE: next week (UNCLASSIFIED)

Date: Thursday, January 24,2013 5:15:18 PM

Josh,

I have US Brown at Fort Campbell starting Monday 4 February, and I'll need
to be there at least one day early to brief the attorney. I don't know that
even if I had a few hours on Saturday I could get done what I need to do.

Trent

Trent Struttmann

Cyber Agents, Inc.

616 Pasadena Dr
Lexington, KY 40503
Office: +1 859 523 9081
Mobile: +1 859 368 2040





From: Tooman, Joshua CPT USARMY

Sent: Thursday, January 24, 2013 4:43 PM
To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV

CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV
USARMY ATEC Prather, Jay CIV USARMY HQDA Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Cc: David Coombs Trent Struttmann;
USARMY USAMDW (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Sir

I am available over the weekend. The following Monday we have interviews in
the morning at the Department of State, but am available in the afternoon.

Trent, are you able to stay through knock this out over the weekend or at
the beginning of the following week?

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 1:58 PM

To: Hall, Cassius CIV CIV Hurley, Thomas

MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV
USARMY HQDA Tooman, Joshua CPT USARMY Smith, Lillian CIV

Page 1441 of2169

02765

USARMY HQDA ITA EM (US)
Subject: RE: next week (UNCLASSIFIED)

Gents,

At this point with such short notice we can get the infrastructure set for
the end of the week, but I do not think Mr. Prather is available the second
half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel,
Charles CIV USARMY ATEC Prather, Jay CIV USARMY HQDA Fein,
Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Smith, Lillian
CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts
(SME), to support next week visit for the forensics. If they are unable to
provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support
for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw am
Subject: RE: next week (UNCLASSIFIED)

Page 1442 of 2169

02766

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we
can schedule another time.



From: CIV (US)

Sent: Thursday, January 24, 2013 1:00 PM

To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM Prather, Jay CIV USARMY HQDA (US)

Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw (us)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1443 of 2169

02767

This is the week they were schedule to come. If your team cannot provide

someone, recommend we cancel, but they may already have their transportation
scheduled.



From: CIV (US)

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay

CIV USARMY HQDA (US)

Cc:? USARMY USAMDW USARMY
(US)

Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records
in City Monday.

What day/time are you looking at. Understand your still coordinating but
those 2 events above are non-?exible.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23, 2013 15:24
To: Hall, Cassius CIV Prather, Jay CIV USARMY HQDA -

CIV (US)
Cc: USARMY USAMDW USARMY

(US)



Page 1444 of 2169

02768

Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the

Classi?cation: UNCLASSIFIED

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1445 of 2169

02769

From: David Coombs
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY
Overgaard, Angel CPT USARMY Tooman, Joshua CPT USARMY (US)

Subject: RE: Mail

Date: Thursday, January 24, 2013 5:08:42 PM



Ashden,
Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW
Sent: Thursday, January 24, 2013 5:04 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY USARMY Overgaard, Angel CPT
USARMY Tooman, Joshua CPT USARMY (US)

Subject: RE: Mail

David,

The mail the PFC BM receives at the JRCF will start getting forward to the
Commander and the unit will collect it. The mail will then be taken to PFC
BM during command visits. This will alleviate the issue of having to

forward any mail from now onto and from different locations and ensure PFC
BM receives his mail no matter where he is housed.

v/r

Ashden


From: David Coombs [m il rm i

Page 1446 of 2169

Sent: Friday, January 18, 2013 2:09 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY USARMY Overgaard, Angel CPT
USARMY Tooman, Joshua CPT USARMY (US)

Subject: Mail

Ashden,

The JRCF is now forwarding mail to Howard County. Given the volume of mail,
it may be better for them to forward it to the unit to avoid any security
concerns.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.

Page 1447 of 2169

02770

02771

From: Fein, Ashden MAJ USARMY MDW

To: Tooman, ,1ng Hall, Qa??m? QIV CIV Hurray, Thomas
MAJ LJSARMY ni I r IV ARMY ATE Prather, Jay QIV LJSARMY HQDA Smith,
Lilli IV ARMY DA ITA EM

Cc: David Coombs Trent Struttmann;? USARMY
USAMDW

Subject: RE: next week (UNCLASSIFIED)

Date: Thursday, January 24, 2013 5:06:00 PM





Also - Mr. Prather are you available over the weekend or at the beginning of
the following week?



From: Tooman, Joshua CPT USARMY (US)

Sent: Thursday, January 24, 2013 4:43 PM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV

CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV
USARMY ATEC Prather, Jay CIV USARMY HQDA Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Cc: David Coombs Trent Struttmann;
USARMY USAMDW (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Sir

I am available over the weekend. The following Monday we have interviews in
the morning at the Department of State, but am available in the afternoon.

Trent, are you able to stay through knock this out over the weekend or at
the beginning of the following week?

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 1:58 PM

To: Hall, Cassius CIV CIV Hurley, Thomas

MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV
USARMY HQDA Tooman, Joshua CPT USARMY Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Gents,
At this point with such short notice we can get the infrastructure set for
the end of the week, but I do not think Mr. Prather is available the second

half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



Page 1448 of 2169

02772

From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel,
Charles CIV USARMY ATEC Prather, Jay CIV USARMY HQDA Fein,
Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Smith, Lillian
CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts
(SME), to support next week visit for the forensics. If they are unable to
provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support
for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw am
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we
can schedule another time.



From: cw
Sent: Thursday, January 24, 2013 1:00 PM

Page 1449 of 2169

02773

To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM Prather, Jay CIV USARMY HQDA (US)

Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

This is the week they were schedule to come. If your team cannot provide
someone, recommend we cancel, but they may already have their transportation
scheduled.



From: CIV (US)

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay

CIV USARMY HQDA (US)

Cc:? USARMY USAMDW USARMY
(US)

Subject: RE: next week

Page 1450 of 2169

02774

Ashden;

Next week is JAMMED for me and Jay next week.

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records
in City Monday.

What day/time are you looking at. Understand your still coordinating but
those 2 events above are non-?exible.



From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23; 2013 15:24
To: Hall; Cassius CIV Prather; Jay USARMY HQDA -

CIV (US)
USARMY USAMDW USARMY








Cc:
(US)
Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the

Classi?cation: UNCLASSIFIED

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED

Page 1451 of2169

02775

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1452 of 2169

02776

From: Fein, Ashden MAJ USARMY MDW (US)
To: "David
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY
Overgaard, Angel CPT USARMY Tooman, Joshua CPT USARMY (US)







Mitroka Katherine
CPT USARMY (US)
Subject: RE: Mail
Date: Thursday, January 24, 2013 5:04:00 PM
David,

The mail the PFC BM receives at the JRCF will start getting forward to the Commander and the unit will collect it.
The mail will then be taken to PFC BM during command visits. This will alleviate the issue of having to forward
any mail from now on to and from different locations and ensure PFC BM receives his mail no matter where he is
housed.

v/r
Ashden



From: David Coombs [mailtozcoombs arm c0urtmartialdefense.c0m]

Sent: Friday, January 18, 2013 2:09 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY

USARMY Overgaard, Angel CPT USARMY Tooman, Joshua CPT USARMY (US)

Subject: Mail

Ashden,

The JRCF is now forwarding mail to Howard County. Given the volume of mail,
it may be better for them to forward it to the unit to avoid any security
concerns.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1453 of 2169

02777

Page 1454 of 2169

02778

From: Tooman, Joshua CPT USARMY

TO: in A MA ARMY MDW HallI Qa?siu? QIV CIV Hurley, Ttha?
MAJ LJSARMY ni I r IV ARMY ATE Pralhgr, Jay QIV LJSARMY HQDA Smilh,
Lilli IV ARMY DA ITA EM

Cc: David Coombs Trent Struttmann;? USARMY
USAMDW

Subject: RE: next week (UNCLASSIFIED)

Date: Thursday, January 24, 2013 4:43:24 PM





Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Sir

I am available over the weekend. The following Monday we have interviews in
the morning at the Department of State, but am available in the afternoon.

Trent, are you able to stay through knock this out over the weekend or at
the beginning of the following week?

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 1:58 PM

To: Hall, Cassius CIV CIV Hurley, Thomas

MAJ USARMY Ganiel, Charles CIV USARMY ATEC Prather, Jay CIV
USARMY HQDA Tooman, Joshua CPT USARMY Smith, Lillian CIV
USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Gents,

At this point with such short notice we can get the infrastructure set for
the end of the week, but I do not think Mr. Prather is available the second
half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel,
Charles CIV USARMY ATEC Prather, Jay CIV USARMY HQDA Fein,
Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Smith, Lillian
CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts

(SME), to support next week visit for the forensics. If they are unable to
provide support, recommend we reschedule at a later date determined by

Page 1455 of 2169

Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support
for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw (us)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we
can schedule another time.



From: CIV (US)
Sent: Thursday, January 24, 2013 1:00 PM
To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA

ITA EM Prather, Jay CIV USARMY HQDA (US)
Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..

Page 1456 of 2169

02779



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA
ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

This is the week they were schedule to come. If your team cannot provide
someone, recommend we cancel, but they may already have their transportation
scheduled.



From: CIV (US)

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay
CIV USARMY HQDA (US)

cc=? USAM (usx? USAM

(US)
Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records
in City Monday.

Page 1457 of 2169

02780

02781

What day/time are you looking at. Understand your still coordinating but
those 2 events above are non-?exible.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23, 2013 15:24
To: Hall, Cassius CIV Prather, Jay USARMY HQDA -

CIV (US)
Cc: USARMY USAMDW USARMY

(US)
Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the
Classi?cation: UNCLASSIFIED

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1458 of 2169

02782

Page 1459 of 2169

02783

From: Hall, Cassius CIV (US)
To: in A MA ARMY MDW rl Th FMA ARMY
nil rl IV ARMYATE ;Pr hr IV ARMYH DA PT
LJSARMY Smith, Lillian g; QIV LJSARMY HQDA ITA EM (L13)
Subject: RE: next week (UNCLASSIFIED)
Date: Thursday, January 24, 2013 2:33:20 PM



Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

MAJ Fein,
Defense SME's are standing by, please send contact Ms? she is not in today. Thanks



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Thursday, January 24, 2013 1:58 PM

To: Hall, Cassius CIV CIV Hurley, Thomas MAJ USARMY Ganiel,
Charles CIV USARMY ATEC Prather, Jay CIV USARMY HQDA Tooman, Joshua CPT
USARMY Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Gents,

At this point with such short notice we can get the infrastructure set for the end of the week, but I do not think Mr.
Prather is available the second half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV USARMY
ATEC Prather, Jay CIV USARMY HQDA Fein, Ashden MAJ USARMY MDW Tooman,
Joshua CPT USARMY Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts (SME), to support next week visit for
the forensics. If they are unable to provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your #7

Page 1460 of 2169

02784



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw am
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we can schedule another time.



From: CIV (US)

Sent: Thursday, January 24, 2013 1:00 PM

To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM Prather,
Jay CIV USARMY HQDA (US)

Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..

Page 1461 of2169

02785



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

This is the week they were schedule to come. If your team cannot provide someone, recommend we cancel, but
they may already have their transportation scheduled.


From: cw
Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay CIV USARMY HQDA
(US)

cc=? USARMY USAMDW wsx? USARMY (Us

Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records in City Monday.

What day/time are you looking at. Understand your still coordinating but those 2 events above are non-?exible.

Page 1462 of 2169

02786



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23, 2013 15:24

To: Hall, Cassius CIV Prather, Jay CIV USARMY HQDA CIV (US)
Cc: USARMY USAMDW USARMY (US)
Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1463 of 2169

02787

From: Fein, Ashden MAJ USARMY MDW (US)
To: i IV r Th FMA ARMY ;Qanigl, Qha?asd

QIV LJSARMY ATEQ Pralhgr, Jay QIV LJSARMY HQDA PT ARMY Smilh,
Lilli IV ARMYH DA ITA EM



Subject: RE: next week (UNCLASSIFIED)
Date: Thursday, January 24, 2013 1:57:00 PM
Gents,

At this point with such short notice we can get the infrastructure set for the end of the week, but I do not think Mr.
Prather is available the second half of the week. What about the weekend or following Monday?

v/r
MAJ Fein



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 1:43 PM

To: CIV Hurley, Thomas MAJ USARMY Ganiel, Charles CIV USARMY
ATEC Prather, Jay CIV USARMY HQDA Fein, Ashden MAJ USARMY MDW Tooman,
Joshua CPT USARMY Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts (SME), to support next week visit for
the forensics. If they are unable to provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your



From: Hall, Cassius CIV (US)
Sent: Thursday, January 24, 2013 13:03

Toz?cwwm

Page 1464 of 2169

02788

Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we can schedule another time.



From: CIV (US)

Sent: Thursday, January 24, 2013 1:00 PM

To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM Prather,
Jay CIV USARMY HQDA (US)

Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw (us)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

This is the week they were schedule to come. If your team cannot provide someone, recommend we cancel, but

Page 1465 of 2169

02789

they may already have their transportation scheduled.


From: cw (Us

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay CIV USARMY HQDA
(US)

cc=? USARMY USAMDW (usx? USARMY (Us

Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records in City Monday.

What day/time are you looking at. Understand your still coordinating but those 2 events above are non-?exible.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23, 2013 15:24

To: Hall, Cassius CIV Prather, Jay CIV USARMY HQDA CIV (US)
Cc: USARMY USAMDW USARMY (US)
Subject: next week

Gents- do you want to use Cass's of?ce at Metro park for the

Classi?cation: UNCLASSIFIED

Page 1466 of 2169

02790

Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1467 of 2169

02791

From: Hall, Cassius CIV (US)
To: rl Th FMA ARMY nil rl IV ARMYATE

Pralhgr, (Jay QIV LJSARMY HQDA in A MA ARMY MDW TQQman, (Joshua ,1 QPT LJSARMY
mi Lilli IV ARMYH DAITA EM

Subject: RE: next week (UNCLASSIFIED)
Date: Thursday, January 24, 2013 1:42:58 PM



Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

There seems to be a scheduling problem for the Prosecution Security Experts (SME), to support next week visit for
the forensics. If they are unable to provide support, recommend we reschedule at a later date determined by
Defense/Prosecution leadership.

The Defense Security Matter Experts (SME), are prepared, to provide support for the forensic piece.

Thanks



From: CIV (US)
Sent: Thursday, January 24, 2013 1:18 PM
To: Hall, Cassius CIV (US)

Subject: RE: next week (UNCLASSIFIED)

Whats your



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 13:03
To: cw ms)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Jay was aware of their visit, but I will contact CPT Tooman and see if we can schedule another time.



From: CIV (US)

Sent: Thursday, January 24, 2013 1:00 PM

To: Hall, Cassius CIV (US)

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM Prather,
Jay CIV USARMY HQDA (US)

Page 1468 of 2169

02792

Subject: RE: next week (UNCLASSIFIED)

Cass,

Those dates below cant be changed.

If we would have got an advance notice maybe ..



From: Hall, Cassius CIV (US)

Sent: Thursday, January 24, 2013 12:56

To: cw

Cc: Ganiel, Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)
Subject: RE: next week (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

This is the week they were schedule to come. If your team cannot provide someone, recommend we cancel, but
they may already have their transportation scheduled.



From: CIV (US)

Sent: Thursday, January 24, 2013 5:48 AM

To: Fein, Ashden MAJ USARMY MDW Hall, Cassius CIV Prather, Jay CIV USARMY HQDA
(US)

cc=? USAM (usx? USAM am

Subject: RE: next week

Ashden,

Next week is JAMMED for me and Jay next week.

Page 1469 of 2169

02793

Jay is at APG 29-31 for G2 business.

I will be at board member orientation for the Army Board of Military Records in City Monday.

What day/time are you looking at. Understand your still coordinating but those 2 events above are non-?exible.



From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Wednesday, January 23, 2013 15:24

To: Hall, Cassius CIV Prather, Jay CIV USARMY HQDA CIV (US)
Cc: USARMY USAMDW USARMY (US)

Subject: next week




Gents- do you want to use Cass's of?ce at Metro park for the

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Classi?cation: UNCLASSIFIED
Caveats: My Default Caveat

Page 1470 of 2169

02794



From: David Coombs

To: CIV USARMY MCCOE (US): Fain, Ashden MAJ USARMY MDW Tooman, ,(gghua QPT
USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Overgaard, Angel CPT USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
us ;??c_xusmwusxwow us
Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Date: Thursday, January 24, 2013 10:06:02 AM

Attachments: Declaration.docx





Mr.-

I have made the requested changes to your declaration. If you identify any
additional substantive changes that are needed, please let the Government
and myself know so that we can set up another conference call.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.


From:



CIV USARMY MCCOE (US)





Sent: Wednesday, January 23, 2013 11:23 AM

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

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

USARMY USARMY USAMDW (US)

Subject: RE: Teleconference Scheduled (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Got it.
Regards,



Page 1471 of2169



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:11 AM

To: CIV USARMY MCCOE
Tooman, Joshua CPT USARMY (US)

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

USARMY USARMY USAMDW (US)

Subject: Teleconference Scheduled

Importance: High

Mr. - Mr. Coombs, CPT Tooman,

A teleconference bridge is reserved starting tomorrow, 24 January 2013, at
0900 and ending at 1000. The dial-in instructions are:



Note: When you dial, you will be asked to input this PASSCODE:
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

V/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1472 of 2169

02795

02796

From: Fein, Ashden MAJ USARMY MDW (US)
To: vi
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT

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

Mitroka Katherine

CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)
Date: Wednesday, January 23, 2013 4:09:00 PM

Attachments: AE470-130116-Ruling (Government Motion to Preclude Motive Evidence).gdf
AE472-130116-Ruling (Judicial Notice Motions).gdf
AE473-130116-Ruling (Defense Motion to CoerI?(?
AE453-121220-Order (Schedule).gdf
AE461-130107-Ruling (Article 13).pdf
AE466-Order (Scheduling).gdf



Bcc:





David,
The rulings are attached.

v/r

Ashden



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Wednesday, January 23, 2013 2:50 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT
USARMY USARMY Overgaard, Angel CPT USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Ashden,

Can you send me digital copies of the COL Lind's rulings from our last
session?

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1473 of 2169

02797



From: Fein, Ashden MAJ USARMY MDW

Sent: Monday, January 21, 2013 11:33 AM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY Overgaard, Angel CPT USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

David,
We will be able to send you the digital versions tomorrow.

v/r

Ashden



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Friday, January 18, 2013 10:55 AM

To: Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY

USARMY Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Angel,

Just let me know once you have the dates. On a side note, can you send me
copies of COL Lind's rulings from our last session? Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Page 1474 of 2169

02798

Sent: Thursday, January 17; 2013 2:34 PM

To. 1% CW (US)

Cc: Hurley, Thomas USARMY Tooman; Joshua CPT USARMY
Morrow; JoDean (Joe) CPT USARMY USAMDW Whyte; Hunter CPT USARMY
von Elten; Alexander (Alec) CPT USARMY

USARMY 'David Coombs'; Fein; Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All;
Mr. - and I spoke today and agreed to reschedule for next week. He
will send out his availability either this week or early next week. Then; we
can agree on a time for a teleconference that works for all of us after
Monday.

Thank you.

VR

ANGEL M. OVERGAARD
JA

Trial Counsel; MDW



From: - - cw (Us
Sent: Wednesday, Janua 2013 8:51 AM

To: Overgaard; Angel CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Angel Overgaard;

I am available Thursday from 0900--1200 EST. l400--l600 EST.
I am available Friday from ll30--l600 EST.

Monday is a Federal Holiday; Martin Luther King Jr. Day.

Re gards,

Center for Army Lessons Learned
rm mil 2 11

US. Army Combined Arms Center
Fort Leavenworth; KS. 66027



Page 1475 of 2169

02799



From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 14, 2013 3:58 PM

To: - - CIV David Coombs; Fein, Ashden MAJ USARMY
MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr.-

Please let us know what times work for you this week. We are in court
Wednesday and Thursday, but we could possibly schedule something during the
lunch hour. Thank you!

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW



From: - - CIV (US)

Sent: Monday, January l4 13 2:38 PM

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

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

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

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

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
I am sorry, I am taking leave for the rest of the day, Monday Jan 14. I
will not be available for today's teleconference.

Request we postpone this meeting for later this week. I am sorry for the
delay.
I will be back in the of?ce Tuesday January 15th.

Regards,

5



From: David Coombs [m il rm i
Sent: Monday, January 14, 2013 7:51 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Page 1476 of 2169

02800

Cc: Hurley, Thomas MAJ USARMY Tooman; Joshua CPT USARMY
Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard; Angel CPT
USARMY Whyte; Hunter CPT USARMY von Elten; Alexander (Alec)
CPT USAM (usx? USAPMY (usx- -
CIV (US) 6
Subject: RE: Teleconference (UNCLASSIFIED)

Ashden;
Thank you.

Best;
David

David E. Coombs; Esq.

Law Of?ce 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



Notice: This transmission; including attachments; may
contain con?dential attomey-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 prohibited.



From: Fein; Ashden MAJ USARMY MDW

Sent: Monday; January 14; 2013 8:41 AM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

All

7

A teleconference bridge is reserved starting at 1500 today. The dial-in
instructions are:



Note: When you dial; you will be asked to input this PASSCODE:
Afterwards; dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

v/r
MAJ Fein

Page 1477 of 2169

02801



From: - cw (Us
Sent: Friday, January 11; 3 4:40 PM

To: Fein; Ashden MAJ USARMY MDW (US)

Cc: David Coombs; Hurley, Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

MAJ Fein;

Yes; I am available at 1500 EST (1400 CST), Monday January 14th. For the
remainder of the week; I am available Tuesday through Friday 0800--l600 EST
(0700--1500 CST).

Re gards,

5

Center for Army Lessons Learned
rm mil 2 11

US. Army Combined Arms Center
Fort Leavenworth; KS. 66027




From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Friday; January 11; 2013 2:58 PM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;
Alexander (Alec) CPT USARMY USARMY (US)
Subject: Teleconference

Importance: High

Mr.-

Thank you for the phone conversation. Are you available on Monday at 15 00
EST for a conference call between defense counsel (Mr. Coombs) and the
government prosecutors?

v/r
MAJ Fein

Page 1478 of 2169

02802

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1479 of 2169

02803

From: FeinI Ashden MAJ USARMY MDW (US)
To: TQQman, L13ARMY Pr IV ARMY DA MerQw, l1g2Dean (,1Qe) LEPT

L13ARMY L13AMDW Qvergaard, Angel LEPT L13ARMY Whyte, l1 H()n1er LEPT L13ARMY
Al AI PT ARMY

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV USARMY USAMDW Trent Struttmann; Ganiel
Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)



Bee:
USARMY MDW CIV Mitroka, Katherine CPT
USARMY (US)

Subject: RE: Forensics

Date: Wednesday, January 23, 2013 3:23:00 PM



Thanks. We will start working ASAP- starting with metro park.



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 3:21 PM

To: Fein, Ashden MAJ USARMY MDW Prather, Jay CIV USARMY HQDA Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV USARMY USAMDW Trent Struttmann; Ganiel,

Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: Forensics

Sir
Any day next week works for us. Trent is the only one who is coming.
Thanks.

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 2:45 PM

To: Tooman, Joshua CPT USARMY Prather, Jay CIV USARMY HQDA Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV USARMY USAMDW Trent Struttmann; Ganiel,

Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: Forensics

Josh,
We need more than 2 duty days to coordinate the SCIF and the entrance requirements. We will start working on

getting the location and other administrative issues resolved, but I highly doubt we can have all that by Monday,
especially considering the witness travel is not coordinated yet. Is Trent Struttmann the only one coming?

v/r
MAJ Fein


From: Tooman, Joshua CPT USARMY (US)
Sent: Wednesday, January 23, 2013 2:04 PM

Page 1480 of 2169

02804

To: Fein, Ashden MAJ USARMY MDW Prather, Jay CIV USARMY HQDA Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV

CIV USARMY USAMDW Trent Struttmann; Ganiel,
Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)
Subject: RE: Forensics

Sir

Right now the plan is for our expert to come in next Monday (28 JAN) and depart Friday (1 FEB). Our preference
is to review the evidence requiring Mr. Prather's presence on 28 January.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:08 AM

To: Prather, Jay CIV USARMY HQDA Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

All,
Good morning. I think there is confusion on the requirements. Subject to the government's discovery production
letter, dated 3 August 2012, and the Court's order dated 8 Nov 12, only the forensic review of the ?les provided on
a separate laptop must be supervised by Mr. Prather and a defense security expert.

The prosecution currently has possession of the laptop and will coordinate with Mr. Prather to make the laptop
available on the preferred day. The laptop has the digital images and the software already installed and ready to
go. The analysis must occur in a SCIF, which the prosecution will ?nd and pre-clear for the laptop's entrance and
visitor access for the defense forensic experts; however the defense will need to escort the defense forensic experts
because they do not have TS clearances.

Please let us know what date so we can start coordinating because this will take a few days to obtain the
authorizations. Thank you!

v/r
MAJ Fein



From: Prather, Jay CIV USARMY HQDA (US)

Sent: Wednesday, January 23, 2013 7: 17 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

My understanding is that it will take place 28 Jan on Ft. not recall what

Page 1481 of2169

02805

In my discussions with Mr. Hall, and recall of the Court Order, this review should not require 5 days

and should be able to be complete in one day ..I bring this up due to obligations at APG 29 - 31 Jan.

V/r

Jay R. Prather



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, January 21, 2013 12:00 PM

To: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
Prather, Jay CIV USARMY HQDA CIV (US)

Subject: RE: Forensics

Josh,

The review of the one laptop with three digital images requires Mr. Prather being present according to the Court's
order. Once you ?gure out the date, we will coordinate for the facility and to have the laptop brought to the
location.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, January 18, 2013 1:04 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV (US)
Subject: Forensics

Sir

We plan to have our forensics guys do a review of the remaining evidence at the end of this month. Does any of that
evidence require the presence of Mr. Prather?

Page 1482 of 2169

02806

Thanks,

Josh

Page 1483 of 2169

02807

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW PraLher, Jay LEIV L13ARMY HQDA Morrow, JoDean (Joe) LEPT

L13ARMY L13AMDW Qvergaard, Angel LEPT L13ARMY WhyLe, l1 HunLer LEPT L13ARMY
Al AI PT ARMY
Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV USARMY USAMDW Trent Struttmann; Ganiel
Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)





Subject: RE: Forensics
Date: Wednesday, January 23, 2013 3:20:41 PM
Sir

Any day next week works for us. Trent is the only one who is coming.
Thanks.

Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 2:45 PM

To: Tooman, Joshua CPT USARMY Prather, Jay CIV USARMY HQDA Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
USARMY USAMDW Trent Struttmann; Ganiel,

Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: Forensics

Josh,

We need more than 2 duty days to coordinate the SCIF and the entrance requirements. We will start working on
getting the location and other administrative issues resolved, but I highly doubt we can have all that by Monday,
especially considering the witness travel is not coordinated yet. Is Trent Struttmann the only one coming?

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 2:04 PM

To: Fein, Ashden MAJ USARMY MDW Prather, Jay CIV USARMY HQDA Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
USARMY USAMDW Trent Struttmann; Ganiel,

Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: Forensics

Sir

Right now the plan is for our expert to come in next Monday (28 JAN) and depart Friday (1 FEB). Our preference
is to review the evidence requiring Mr. Prather's presence on 28 January.

Thanks,
Josh

Page 1484 of 2169

02808



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:08 AM

To: Prather, Jay CIV USARMY HQDA Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

All,
Good morning. I think there is confusion on the requirements. Subject to the government's discovery production

letter, dated 3 August 2012, and the Court's order dated 8 Nov 12, only the forensic review of the ?les provided on
a separate laptop must be supervised by Mr. Prather and a defense security expert.

The prosecution currently has possession of the laptop and will coordinate with Mr. Prather to make the laptop
available on the preferred day. The laptop has the digital images and the software already installed and ready to
go. The analysis must occur in a SCIF, which the prosecution will ?nd and pre-clear for the laptop's entrance and
visitor access for the defense forensic experts; however the defense will need to escort the defense forensic experts
because they do not have TS clearances.

Please let us know what date so we can start coordinating because this will take a few days to obtain the
authorizations. Thank you!

v/r
MAJ Fein



From: Prather, Jay CIV USARMY HQDA (US)

Sent: Wednesday, January 23, 2013 7:17 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

My understanding is that it will take place 28 Jan on Ft. not recall what

In my discussions with Mr. Hall, and recall of the Court Order, this review should not require 5 days

and should be able to be complete in one day ..I bring this up due to obligations at APG 29 - 31 Jan.

V/r

Jay R. Prather

Page 1485 of 2169

02809



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, January 21, 2013 12:00 PM

To: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
Prather, Jay CIV USARMY HQDA CIV (US)

Subject: RE: Forensics

Josh,

The review of the one laptop with three digital images requires Mr. Prather being present according to the Court's
order. Once you ?gure out the date, we will coordinate for the facility and to have the laptop brought to the
location.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, January 18, 2013 1:04 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV (US)
Subject: Forensics

Sir

We plan to have our forensics guys do a review of the remaining evidence at the end of this month. Does any of that
evidence require the presence of Mr. Prather?

Thanks,

Josh

Page 1486 of 2169

02810

From: David Coombs
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT

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



Subject: RE: Teleconference (UNCLASSIFIED)
Date: Wednesday, January 23, 2013 2:51:16 PM
Ashden,

Can you send me digital copies of the COL Lind's rulings from our last
session?

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Monday, January 21, 2013 11:33 AM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY Overgaard, Angel CPT USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

David,

We will be able to send you the digital versions tomorrow.

v/r

Ashden



From: David Coombs com]

Sent: Friday, January 18, 2013 10:55 AM
To: Overgaard, Angel CPT USARMY (US)
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

Page 1487 of 2169

02811

Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Angel,

Just let me know once you have the dates. On a side note, can you send me
copies of COL Lind's rulings from our last session? Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Sent: Thursday, January 17, 2013 2:34 PM

To. 1% CW (US)

Cc: Hurley, Thomas USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY

USARMY 'David Coombs'; Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
Mr. - and I spoke today and agreed to reschedule for next week. He
will send out his availability either this week or early next week. Then, we
can agree on a time for a teleconference that works for all of us after
Monday.

Thank you.

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Page 1488 of 2169

02812



From=-- cw
Sent: Wednesday, Janua 6 2013 8:51 AM

To: Overgaard, Angel CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Angel Overgaard,

I am available Thursday from 0900--1200 EST. l400--l600 EST.
I am available Friday from ll30--l600 EST.

Monday is a Federal Holiday, Martin Luther King Jr. Day.

Regards,

Center for Army Lessons Learned
rm mil 2 11

US. Army Combined Arms Center
Fort Leavenworth, KS. 66027





From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 14, 2013 3:58 PM

To: - - CIV David Coombs; Fein, Ashden MAJ USARMY
MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr.-

Please let us know what times work for you this week. We are in court
Wednesday and Thursday, but we could possibly schedule something during the
lunch hour. Thank you!

VR
ANGEL M. OVERGAARD

Page 1489 of 2169

CPT, JA
Trial Counsel, MDW



From: - - cw (Us
Sent: Monday, January l4 13 2:38 PM

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

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

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

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

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
I am sorry, I am taking leave for the rest of the day, Monday Jan 14. I
will not be available for today's teleconference.

Request we postpone this meeting for later this week. I am sorry for the
delay.
I will be back in the of?ce Tuesday January 15th.

Regards,

5



From: David Coombs [m il rm i

Sent: Monday, January 14, 2013 7:51 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

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

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

CPT USARMY USARMY -

CIV (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Ashden,
Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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 1490 of 2169

02813

02814

Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Monday, January 14, 2013 8:41 AM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

All

7

A teleconference bridge is reserved starting at 1500 today. The dial-in
instructions are:



Note: When you dial, you will be asked to input this PASSCODE:
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

v/r
MAJ Fein



From: - cw (Us
Sent: Friday, January 11, 3 4:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

MAJ Fein,

Yes, I am available at 1500 EST (1400 CST), Monday January 14th. For the
remainder of the week, I am available Tuesday through Friday 0800--l600 EST
(0700--1500 CST).

Regards,



Page 1491 of2169

02815

Center for Army Lessons Learned
http://usacacarmy mil/cac2/call/

US. Army Combined Arms Center
Fort Leavenworth, KS. 66027




From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Friday, January 11; 2013 2:58 PM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;
Alexander (Alec) CPT USARMY USARMY (US)
Subject: Teleconference

Importance: High

Mr.-

Thank you for the phone conversation. Are you available on Monday at 1500
EST for a conference call between defense counsel (Mr. Coombs) and the
government prosecutors?

v/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1492 of 2169

02816

Page 1493 of 2169

02817

From: Fein, Ashden MAJ USARMY MDW (US)
To: TQQman, L13ARMY Pr IV ARMY DA MerQw, l1g1Dean ((1953) LEPT

L13ARMY L13AMDW Qvergaard, Angel LEPT L13ARMY Whyte, l1 HLinLer LEPT L13ARMY
Al AI PT ARMY
Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV USARMY USAMDW Trent Struttmann; Ganiel
Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)





Bcc:
USARMY MDW CIV Mitroka, Katherine CPT
USARMY (US)

Subject: RE: Forensics

Date: Wednesday, January 23, 2013 2:43:00 PM

Josh,

We need more than 2 duty days to coordinate the SCIF and the entrance requirements. We will start working on
getting the location and other administrative issues resolved, but I highly doubt we can have all that by Monday,
especially considering the witness travel is not coordinated yet. Is Trent Struttmann the only one coming?

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Wednesday, January 23, 2013 2:04 PM

To: Fein, Ashden MAJ USARMY MDW Prather, Jay CIV USARMY HQDA Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV USARMY USAMDW Trent Struttmann; Ganiel,

Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)

Subject: RE: Forensics

Sir

Right now the plan is for our expert to come in next Monday (28 JAN) and depart Friday (1 FEB). Our preference
is to review the evidence requiring Mr. Prather's presence on 28 January.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:08 AM

To: Prather, Jay CIV USARMY HQDA Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

All,
Good morning. I think there is confusion on the requirements. Subject to the government's discovery production

letter, dated 3 August 2012, and the Court's order dated 8 Nov 12, only the forensic review of the ?les provided on
a separate laptop must be supervised by Mr. Prather and a defense security expert.

Page 1494 of 2169

02818

The prosecution currently has possession of the laptop and will coordinate with Mr. Prather to make the laptop
available on the preferred day. The laptop has the digital images and the software already installed and ready to
go. The analysis must occur in a SCIF, which the prosecution will ?nd and pre-clear for the laptop's entrance and
visitor access for the defense forensic experts; however the defense will need to escort the defense forensic experts
because they do not have TS clearances.

Please let us know what date so we can start coordinating because this will take a few days to obtain the
authorizations. Thank you!

v/r
MAJ Fein



From: Prather, Jay CIV USARMY HQDA (US)

Sent: Wednesday, January 23, 2013 7:17 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV

cw (Us

Subject: RE: Forensics

My understanding is that it will take place 28 Jan on Ft. not recall what

In my discussions with Mr. Hall, and recall of the Court Order, this review should not require 5 days

and should be able to be complete in one day ..I bring this up due to obligations at APG 29 - 31 Jan.

V/r

Jay R. Prather



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, January 21, 2013 12:00 PM

To: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
Prather, Jay CIV USARMY HQDA CIV (US)

Subject: RE: Forensics

Josh,

Page 1495 of 2169

02819

The review of the one laptop with three digital images requires Mr. Prather being present according to the Court's
order. Once you ?gure out the date, we will coordinate for the facility and to have the laptop brought to the
location.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, January 18, 2013 1:04 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV (US)
Subject: Forensics

Sir

We plan to have our forensics guys do a review of the remaining evidence at the end of this month. Does any of that
evidence require the presence of Mr. Prather?

Thanks,

Josh

Page 1496 of 2169

02820

From: Tooman, Joshua CPT USARMY (US)
To: in A MA ARMY MDW Prather, Jay LEIV L13ARMY HQDA Morrow, JoDean (Joe) LEPT

L13ARMY L13AMDW Angel LEPT L13ARMY Whng, l1 HunLgr LEPT L13ARMY
Al AI PT ARMY

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV USARMY USAMDW Trent Struttmann; Ganiel
Charles CIV USARMY ATEC Smith, Lillian CIV USARMY HQDA ITA EM (US)





Subject: RE: Forensics
Date: Wednesday, January 23, 2013 2:03:44 PM
Sir

Right now the plan is for our expert to come in next Monday (28 JAN) and depart Friday (1 FEB). Our preference
is to review the evidence requiring Mr. Prather's presence on 28 January.

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Wednesday, January 23, 2013 9:08 AM

To: Prather, Jay CIV USARMY HQDA Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

All,
Good morning. I think there is confusion on the requirements. Subject to the government's discovery production
letter, dated 3 August 2012, and the Court's order dated 8 Nov 12, only the forensic review of the ?les provided on
a separate laptop must be supervised by Mr. Prather and a defense security expert.

The prosecution currently has possession of the laptop and will coordinate with Mr. Prather to make the laptop
available on the preferred day. The laptop has the digital images and the software already installed and ready to
go. The analysis must occur in a SCIF, which the prosecution will ?nd and pre-clear for the laptop's entrance and
visitor access for the defense forensic experts; however the defense will need to escort the defense forensic experts
because they do not have TS clearances.

Please let us know what date so we can start coordinating because this will take a few days to obtain the
authorizations. Thank you!

v/r
MAJ Fein



From: Prather, Jay CIV USARMY HQDA (US)

Sent: Wednesday, January 23, 2013 7:17 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

Page 1497 of 2169

02821

My understanding is that it will take place 28 Jan on Ft. not recall what

In my discussions with Mr. Hall, and recall of the Court Order, this review should not require 5 days

and should be able to be complete in one day ..I bring this up due to obligations at APG 29 - 31 Jan.

V/r

Jay R. Prather



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, January 21, 2013 12:00 PM

To: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
Prather, Jay CIV USARMY HQDA CIV (US)

Subject: RE: Forensics

Josh,

The review of the one laptop with three digital images requires Mr. Prather being present according to the Court's
order. Once you ?gure out the date, we will coordinate for the facility and to have the laptop brought to the
location.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, January 18, 2013 1:04 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV (US)
Subject: Forensics

Sir

We plan to have our forensics guys do a review of the remaining evidence at the end of this month. Does any of that

Page 1498 of 2169

02822

evidence require the presence of Mr. Prather?

Thanks,

Josh

Page 1499 of 2169

02823





From: Fein, Ashden MAJ USARMY MDW (US)

To: rm i . m; Hurley, Thomas MAJ LJSARMY TQQman, aJoshua ,1 QPT LJSARMY
.05).

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

Mitroka Katherine

CPT USARMY (US)

Subject: Witness Issues

Date: Wednesday, January 23, 2013 10:50:00 AM

I mportance: High

Defense,

I am tracking the below witness administrative issues. Please con?rm so we can get them all resolved ASAP:







Carr - classi?ed interview or not?

- 0900 on Thursday, 24 Jan 13

ajGen McKenzie - need updated contact info

- confused about her authentication testimony
- need updated contact info

- have not returned calls

Mr. Travieso - need updated contact info

LT Hoskins - need updated contact info

Are there any others as of today?

Thank you!

v/r
MAJ Fein

Page 1500 of 2169

02824





From: David Coombs

To: in A MA ARMY MDW CIV USARMY MCCOE (US): Tooman ,mhua
USARMY (US)

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

us ;??c_xusmwuswow us

Subject: RE: Teleconference Scheduled

Date: Wednesday, January 23, 2013 10:23:31 AM

Ashden,

Thank you.

Best,

David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Wednesday, January 23, 2013 10:11 AM

To:

CIV USARMY MCCOE

Tooman, Joshua CPT USARMY (US)

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

USARMY

USARMY USAMDW (US)

Subject: Teleconference Scheduled

Importance: High

Mr. - Mr. Coombs, CPT Tooman,

A teleconference bridge is reserved starting tomorrow, 24 January 2013, at
0900 and ending at 1000. The dial-in instructions are:

Note: When you dial, you will be asked to input this PASSCODE-

Page 1501 of2169

02825

Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

V/r
MAJ Fein

Page 1502 of 2169

From:
To:

Bcc:

Subject:
Date:
I mportance:


LJSARMY

02826

Fein, Ashden MAJ USARMY MDW (US)
CIV USARMY MCCOE (US): TQQman, Joshua QPT

Hurley, Thomas MAJ USARMY Overgaard, Angel CPT USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY USARMY USAMDW US

StichI Katherine MAJ USARMY McCoyI Michael (Mike) CIV USARMY CAC
CIV Mitrokal Katherine CPT USARMY (US)

Teleconference Scheduled
Wednesday, January 23, 2013 10:09:00 AM
High






MDW





Mr. - Mr. Coombs, CPT Tooman,

A teleconference bridge is reserved starting tomorrow, 24 January 2013, at 0900 and ending at 1000. The dial-in
instructions are:



Note: When you dial, you will be asked to input this PASSCODE: - Afterwards, dial the key to join the
conference call. The line will be ready 5 minutes prior to start of teleconference.

V/r
MAJ Fein

Page 1503 of 2169

02827

From: Fein, Ashden MAJ USARMY MDW (US)
To: Prather, (Jay QIV LJSARMY HQDA TQQman, lJoshua ,1 (PT LJSARMY Morrow, lJoDean (Joe) QPT
LJSARMY LJSAMDW An I PT ARMY Whyte, ,1 Hunter QPT LJSARMY Elten,

Al AI PT ARMY



Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)
Bcc:
1&1; USARMY
Mitroka, Katherine CPT USARMY (US)
Subject: RE: Forensics
Date: Wednesday, January 23, 2013 9:06:00 AM

Attachments: 121108-Order (Additional Protective Order for Classified Information) (UNCLAS



All,

Good morning. I think there is confusion on the requirements. Subject to the government's discovery production
letter, dated 3 August 2012, and the Court's order dated 8 Nov 12, only the forensic review of the ?les provided on
a separate laptop must be supervised by Mr. Prather and a defense security expert.

The prosecution currently has possession of the laptop and will coordinate with Mr. Prather to make the laptop
available on the preferred day. The laptop has the digital images and the software already installed and ready to
go. The analysis must occur in a SCIF, which the prosecution will ?nd and pre-clear for the laptop's entrance and
visitor access for the defense forensic experts; however the defense will need to escort the defense forensic experts
because they do not have TS clearances.

Please let us know what date so we can start coordinating because this will take a few days to obtain the
authorizations. Thank you!

v/r
MAJ Fein



From: Prather, Jay CIV USARMY HQDA (US)

Sent: Wednesday, January 23, 2013 7:17 AM

To: Fein, Ashden MAJ USARMY MDW Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)

CPT USARMY USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY

von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
CIV (US)

Subject: RE: Forensics

My understanding is that it will take place 28 Jan on Ft. not recall what

In my discussions with Mr. Hall, and recall of the Court Order, this review should not require 5 days

and should be able to be complete in one day ..I bring this up due to obligations at APG 29 - 31 Jan.

V/r

Jay R. Prather

Page 1504 of 2169

02828



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, January 21, 2013 12:00 PM

To: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV
Prather, Jay CIV USARMY HQDA CIV (US)

Subject: RE: Forensics

Josh,

The review of the one laptop with three digital images requires Mr. Prather being present according to the Court's
order. Once you ?gure out the date, we will coordinate for the facility and to have the laptop brought to the
location.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, January 18, 2013 1:04 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV (US)
Subject: Forensics

Sir

We plan to have our forensics guys do a review of the remaining evidence at the end of this month. Does any of that
evidence require the presence of Mr. Prather?

Thanks,

Josh

Page 1505 of 2169

02829

From: Fein, Ashden MAJ USARMY MDW (US)
To:
Cc:

USARMY Overgaard, Angel CPT USARMY Morrow, JoDean (Joe) CPT
USARMY USAMDW Hurley, Thomas MAJ USARMY
Tooman Joshua CPT USARMY US



Bcc:
Mitroka Katherine
CPT USARMY von Elten, Alexander (Alec) CPT USARMY Whyte, Hunter CPT USARMY (US)
Subject: US v. PFC Bradley Manning
Date: Wednesday, January 23, 2013 8:55:00 AM
I mportance: High



Good morning. I am the lead prosecutor for the US. Army court-martial of Private First Class Bradley Manning.
The defense identi?ed you as a witness in this case and informed the Court that they request to share certain
classi?ed information with you during your testimony. In furtherance of this, it is the prosecution's responsibility to

process US. Government security clearances and access requests for you to potentially access classi?ed
information.

To process you for a security clearance, we must have the following information: Full Name, Social Security
Number, Date of Birth, Place of Birth, Country of Citizenship, email address, and telephone number. This
information will not be shared with anyone other than US. Government security personnel that need this
information to process you for a security clearance. This information will be used to process the initial request for
access to the security questionnaire system. Once this request is approved, you will then be required to complete an

online security clearance questionnaire that will be used as part of your comprehensive background investigation to
determine your eligibility.

If you have any questions, please contact me or Chief Warrant Of?cer 2 at_ or via this

email.
Thank you.
Re spect?illy,

Major Fein

Ashden Fein
Major, US. Army

Page 1506 of 2169

02830

From: Tooman, Joshua CPT USARMY (US)

To: in A MA ARMY MDW rr PT ARMY AMDW Angel
QPT LJSARMY Whng, ,1 HunIgr QPT LJSARMY Alexander 5 (Algg) QPT LJSARMY (L15)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV Prather,

Jay CIV USARMY HQDA CIV Trent Struttmann; Ganiel, Charles CIV
USARMY ATEC (US)

Subject: RE: Forensics (UNCLASSIFIED)

Date: Tuesday, January 22, 2013 3:27:47 PM



Classi?cation: UNCLASSIFIED
Caveats: NONE

Sir

Our forensics guys are coming next week, Monday-Friday. We can accommodate
whatever day works best for Mr. Prather. Will Mr. Prather bring the
evidence or do you want me to come pick it up in advance?

Thanks,
Josh



From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, January 21, 2013 12:01 PM

To: Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY

Hall, Cassius Prather, Jay USARMY HQDA -

- (US)

Subject: RE: Forensics
Josh,

The review of the one laptop with three digital images requires Mr. Prather
being present according to the Court's order. Once you ?gure out the date,
we will coordinate for the facility and to have the laptop brought to the
location.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, January 18, 2013 1:04 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY
USAMDW Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY

Hall, Cassius CIV (US)

Subject: Forensics

Sir

Page 1507 of 2169

02831

We plan to have our forensics guys do a review of the remaining evidence at
the end of this month. Does any of that evidence require the presence of
Mr. Prather?

Thanks,

Josh

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1508 of 2169

02832

From: David Coombs
To: vr An IM PT ARMY
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY Fein, Ashden MAJ USARMY MDW USARMY
USAMDW Mitroka, Katherine CPT USARMY (US)





Subject: RE: Teleconference (UNCLASSIFIED)
Date: Tuesday, January 22, 2013 1:19:54 PM
Angel,

I would like to have the call at 0900 if that works for you. I have a
con?ict at 11:00. I could also have the call at 1300.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 21, 2013 6:41 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY

USARMY Fein, Ashden MAJ USARMY MDW

USARMY USAMDW Mitroka, Katherine CPT USARMY (US)

Subject: FW: Teleconference (UNCLASSIFIED)

Sir,

Below are the dates that Mr. - is available. The prosecution would
prefer Thursday with start times between 0800 and 0900 or between 1100 and
1300. Do any of these times work for you? Thank you.

VR

ANGEL M. OVERGAARD
CPT, JA

Page 1509 of 2169

Trial Counsel, MDW

Original Message

From: - cw (us)
Sent: Friday, January 18, 3 08:30 PM

To: Overgaard, Angel CPT USARMY (US)
Cc: McCoy, Michael (Mike) CIV USARMY CAC (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Overgaard,

Mondays and Tuesdays are busy days at CALL. We've shifted things a bit with
the MLK Jr. Day Holiday.

I am available:

Wednesday Jan 23, 1200--1500 EST.
Thursday Jan 24, 0800--1500 EST.

I can't go past 1500 EST.
Can you ask all involved to keep this meeting to one hour?
Please pass on my note.

Thanks,


From: Overgaard, Angel CPT USARMY (US)
Sent: Thursday, January 17, 2013 1:34 PM

To. 1% CIV (US)

Cc: Hurley, Thomas USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY

USARMY 'David Coombs'; Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
Mr. - and I spoke today and agreed to reschedule for next week. He
will send out his availability either this week or early next week. Then, we
can agree on a time for a teleconference that works for all of us after
Monday.

Thank you.

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Page 1510 of2169

02833

02834



From=-- cw
Sent: Wednesday, Janua 6 2013 8:51 AM

To: Overgaard, Angel CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Angel Overgaard,

I am available Thursday from 0900--1200 EST. l400--l600 EST.
I am available Friday from ll30--l600 EST.

Monday is a Federal Holiday, Martin Luther King Jr. Day.

Regards,

Center for Army Lessons Learned
rm mil 2 11

US. Army Combined Arms Center
Fort Leavenworth, KS. 66027





From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 14, 2013 3:58 PM

To: - - CIV David Coombs; Fein, Ashden MAJ USARMY
MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr.-

Please let us know what times work for you this week. We are in court
Wednesday and Thursday, but we could possibly schedule something during the
lunch hour. Thank you!

VR
ANGEL M. OVERGAARD

Page 1511 of2169

CPT, JA
Trial Counsel, MDW



From: - - cw (Us
Sent: Monday, January l4 13 2:38 PM

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

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

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

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

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
I am sorry, I am taking leave for the rest of the day, Monday Jan 14. I
will not be available for today's teleconference.

Request we postpone this meeting for later this week. I am sorry for the
delay.
I will be back in the of?ce Tuesday January 15th.

Regards,

5



From: David Coombs [m il rm i

Sent: Monday, January 14, 2013 7:51 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

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

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

CPT USARMY USARMY -

CIV (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Ashden,
Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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 1512 of2169

02835

02836

Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Monday, January 14, 2013 8:41 AM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

All

7

A teleconference bridge is reserved starting at 1500 today. The dial-in
instructions are:



Note: When you dial, you will be asked to input this PASSCODE: -
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

v/r
MAJ Fein



From: - cw (Us
Sent: Friday, January 11, 3 4:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

MAJ Fein,

Yes, I am available at 1500 EST (1400 CST), Monday January 14th. For the
remainder of the week, I am available Tuesday through Friday 0800--l600 EST
(0700--1500 CST).

Regards,



Page 1513 of2169

02837

Center for Army Lessons Learned
http://usacacarmy mil/cac2/call/

US. Army Combined Arms Center
Fort Leavenworth, KS. 66027
CML 913-684-5983




From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Friday, January 11; 2013 2:58 PM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;

Alexander (Alec) CPT USARMY USARMY (US)

Subject: Teleconference
Importance: High

Mr.-

Thank you for the phone conversation. Are you available on Monday at 1500
EST for a conference call between defense counsel (Mr. Coombs) and the
government prosecutors?

v/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED

Page 1514 of2169

02838

Caveats: NONE

Page 1515 of2169

02839

From: David Coombs
To: vr An IM PT ARMY
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY Fein, Ashden MAJ USARMY MDW USARMY
USAMDW Mitroka, Katherine CPT USARMY (US)





Subject: RE: Teleconference (UNCLASSIFIED)
Date: Tuesday, January 22, 2013 9:58:45 AM
Angel,

Thursday at 1100 will work for me.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 21, 2013 6:41 PM

To: David Coombs

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY

USARMY Fein, Ashden MAJ USARMY MDW

USARMY USAMDW Mitroka, Katherine CPT USARMY (US)

Subject: FW: Teleconference (UNCLASSIFIED)

Sir,

Below are the dates that Mr. - is available. The prosecution would
prefer Thursday with start times between 0800 and 0900 or between 1100 and
1300. Do any of these times work for you? Thank you.

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Page 1516 of2169

Original Message

Fromz--F cw ms)
Sent: Friday, January 18, 6 3 08:30 PM

To: Overgaard, Angel CPT USARMY (US)
Cc: McCoy, Michael (Mike) CIV USARMY CAC (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Overgaard,

Mondays and Tuesdays are busy days at CALL. We've shifted things a bit with
the MLK Jr. Day Holiday.

I am available:

Wednesday Jan 23, 1200--1500 EST.
Thursday Jan 24, 0800--1500 EST.

I can't go past 1500 EST.
Can you ask all involved to keep this meeting to one hour?
Please pass on my note.

Thanks,


From: Overgaard, Angel CPT USARMY (US)
Sent: Thursday, January 17, 2013 1:34 PM

To, CIV (US)

Cc: Hurley, Thomas USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY

USARMY 'David Coombs'; Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
Mr. - and I spoke today and agreed to reschedule for next week. He
will send out his availability either this week or early next week. Then, we
can agree on a time for a teleconference that works for all of us after
Monday.

Thank you.

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW

Page 1517 of2169

02840



From: - - cw (Us
Sent: Wednesday, Janua 2013 8:51 AM

To: Overgaard, Angel CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Angel Overgaard,

I am available Thursday from 0900--1200 EST. l400--l600 EST.
I am available Friday from ll30--l600 EST.

Monday is a Federal Holiday, Martin Luther King Jr. Day.

Regards,

Center for Army Lessons Learned
rm mil 2 11

US. Army Combined Arms Center
Fort Leavenworth, KS. 66027





From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 14, 2013 3:58 PM

To: - - CIV David Coombs; Fein, Ashden MAJ USARMY
MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr.-

Please let us know what times work for you this week. We are in court
Wednesday and Thursday, but we could possibly schedule something during the
lunch hour. Thank you!

VR

ANGEL M. OVERGAARD
CPT, JA

Page 1518of2169

02841

Trial Counsel, MDW



From: - - cw (us)
Sent: Monday, January l4 13 2:38 PM

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

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

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

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

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
I am sorry, I am taking leave for the rest of the day, Monday Jan 14. I
will not be available for today's teleconference.

Request we postpone this meeting for later this week. I am sorry for the
delay.
I will be back in the of?ce Tuesday January 15th.

Regards,

5



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Monday, January 14, 2013 7:51 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY

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

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

CPT USAPMY (usx? USAM (st- -

CIV (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Ashden,
Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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 1519 of2169

02842

02843

Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Monday, January 14, 2013 8:41 AM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

All

7

A teleconference bridge is reserved starting at 1500 today. The dial-in
instructions are:



Note: When you dial, you will be asked to input this PASSCODE:
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

v/r
MAJ Fein



From: - cw am
Sent: Friday, January 11, 3 4:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

MAJ Fein,

Yes, I am available at 1500 EST (1400 CST), Monday January 14th. For the
remainder of the week, I am available Tuesday through Friday 0800--l600 EST
(0700--1500 CST).

Regards,



Page 1520 of 2169

02844

Center for Army Lessons Learned
http://usacacarmy mil/cac2/call/

US. Army Combined Arms Center
Fort Leavenworth, KS. 66027




From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Friday, January 11; 2013 2:58 PM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;
Alexander (Alec) CPT USARMY USARMY (US)
Subject: Teleconference

Importance: High

Mr.-

Thank you for the phone conversation. Are you available on Monday at 1500
EST for a conference call between defense counsel (Mr. Coombs) and the
government prosecutors?

v/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1521 of2169

02845

Page 1522 of 2169

02846

From: Fein, Ashden MAJ USARMY MDW (US)
To: "TQQman, Joshua ,1 QPT rr PT ARMY AMDW ;m

Anggl Wh PT ARMY ;v El Al AI PT ARMY
TQQman, ,1 QPT USARMY Pralhgr, Jay QIV USARMY HQDA CIV
ms); MiIera, Katharina QPT USARMY (us)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV Prather,
Jay CIV CIV











Bcc:
"Mitroka, Katherine CPT USARMY "Morrow, JoDean (Joe) CPT USARMY USAMDW
ll
Subject: RE: Forensics
Date: Monday, January 21, 2013 11:45:00 AM
Josh,

The review of the one laptop with three digital images requires Mr. Prather being present according to the Court's
order. Once you ?gure out the date, we will coordinate for the facility and to have the laptop brought to the
location.

v/r
MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Friday, January 18, 2013 1:04 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW
Overgaard, Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV (US)
Subject: Forensics

Sir

We plan to have our forensics guys do a review of the remaining evidence at the end of this month. Does any of that
evidence require the presence of Mr. Prather?

Thanks,

Josh

Page 1523 of 2169

02847

From: Fein, Ashden MAJ USARMY MDW (US)

To: "Hurley, Thomas MAJ QSD QMQ Defense"; "Rob garr"; Mitrgka, Katherine QPT LJSARMY (LJS)
Cc: Holden, Paul Jr CIV (US)

Bcc:



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





Subject: RE: Defense Counsel Interview
Date: Monday, January 21, 2013 11:37:00 AM
Gentlemen,

I apologize for the confusion. I will discuss this issue with Mr. Holden
tomorrow, if he is available, and hopefully clarify. Thank you!

v/r

Ashden



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Friday, January 18, 2013 8:30 AM

To: 'Rob Carr'

Cc: Holden, Paul Jr CIV Fein, Ashden MAJ USARMY MDW (US)
Subject: RE: Defense Counsel Interview

Sir,

Your accounting of our phone conversation is accurate. I have copied MAJ
Fein, the lead prosecutor, to help us understand what classi?ed information
can be discussed in our interview and what, if any, will be the substance of
your testimony at trial. The defense has been told that you will discuss
classi?ed information.

On location - I have a conference room just outside my of?ce that is
available for our meeting. But I have no problem going to DIA if that would
be easier.

Look forward to meeting you in a week.

v/r
MAJ Hurley



From: Rob Carr

Sent: Thursday, January 17, 2013 5:01 PM

To: Hurley, Thomas MAJ OSD OMC Defense

Cc: Holden Jr, Paul P.
Subject: Defense Counsel Interview

MAJ Hurley,
Per phone conversation.

This is a good e-mail address for me.

Page 1524 of 2169

02848

Ihave blocked 0900 - 1030, Friday, 25 Jan 13.

Will stand by for clari?cation on a location albeit, looking at
or Bolling AFB at this time.

And need a determination on the Classi?cation level for the
discussion.

RAC

Page 1525 of 2169

02849





From: Fein, Ashden MAJ USARMY MDW (US)

To: "Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) QPT USARMY USAMDW Hurley, Thomas
MAJ USARMY (US)

Cc: Tooman, Joshua CPT USARMY

Bcc:

"Mitroka, Katherine CPT USARMY "Morrow, JoDean (Joe) CPT USARMY USAMDW

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

Subject: RE: Witnesses

Date: Monday, January 21, 2013 11:36:00 AM

MAJ Hurley,

I don't know why these FBI witnesses are unavailable. I will check tomorrow. As for MajGen McKenzie- I will try
to contact his of?ce to get better contact info.

V/r
Ashden



From: Hurley, Thomas MAJ USARMY (US)

Sent: Friday, January 18, 2013 12:00 PM

To: Fein, Ashden MAJ USARMY MDW Morrow, JoDean (Joe) CPT USARMY USAMDW (US)
Cc: Tooman, Joshua CPT USARMY

Subject: Witnesses

Gents
There are some problems with the following witnesses:

#82 (MG Kenneth McKenzie) - contact info is bad. I sent him an email through my outlook directly, but I don't
know if it's going to get to him or what he is going to do with it.

#119? - didn't know anything about being a witness. Gave her MAJ Fein's name and number.

#127 - no record of him in DC or Houston. (I don't know why the receptionist transferred
me to Houstonavail.)

(I've only been able to leave messages with& and-, so I don't know if any of these four are aware that
you are calling them as witnesses.)

Please help as soon as you can. For non-?ag of?cers, it may help to give me their email. I ?nd that's the best way
to contact someone. (People ignore voicemails like you wouldn't believe.)

Page 1526 of 2169

02850

Thanks.

MAJ Hurley

Page 1527 of 2169

02851

From: Fein, Ashden MAJ USARMY MDW (US)
To: vi
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT

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

Mitroka Katherine







Bcc:

CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)
Date: Monday, January 21, 2013 11:31:00 AM
David,

We will be able to send you the digital versions tomorrow.

v/r

Ashden



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Friday, January 18, 2013 10:55 AM

To: Overgaard, Angel CPT USARMY (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe)
CPT USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT
USARMY USARMY Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Angel,

Just let me know once you have the dates. On a side note, can you send me
copies of COL Lind's rulings from our last session? Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Page 1528 of 2169

02852

Sent: Thursday, January 17; 2013 2:34 PM

To. 1% CW (US)

Cc: Hurley, Thomas USARMY Tooman; Joshua CPT USARMY
Morrow; JoDean (Joe) CPT USARMY USAMDW Whyte; Hunter CPT USARMY
von Elten; Alexander (Alec) CPT USARMY

USARMY 'David Coombs'; Fein; Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All;
Mr. - and I spoke today and agreed to reschedule for next week. He
will

send out his availability either this week or early next week. Then; we can
agree on a time for a teleconference that works for all of us after Monday.
Thank you.

VR

ANGEL M. OVERGAARD
JA

Trial Counsel; MDW



From: - - cw (Us
Sent: Wednesday, Janua 2013 8:51 AM

To: Overgaard; Angel CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Angel Overgaard;

I am available Thursday from 0900--1200 EST. l400--l600 EST.
I am available Friday from ll30--l600 EST.

Monday is a Federal Holiday; Martin Luther King Jr. Day.

Re gards,

Center for Army Lessons Learned
rm mil 2 11

US. Army Combined Arms Center
Fort Leavenworth; KS. 66027



Page 1529 of 2169

02853



From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 14, 2013 3:58 PM

To: - - CIV David Coombs; Fein, Ashden MAJ USARMY
MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr.-

Please let us know what times work for you this week. We are in court
Wednesday and Thursday, but we could possibly schedule something during the
lunch hour. Thank you!

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW



From: - - CIV (US)

Sent: Monday, January l4 13 2:38 PM

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

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY

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

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All

7

I am sorry, I am taking leave for the rest of the day, Monday Jan 14. I
will not be available for today's teleconference.

Request we postpone this meeting for later this week. I am sorry for the
delay.

I will be back in the of?ce Tuesday January 15th.

Regards,

5


From: David Coombs [m il rm i
Sent: Monday, January 14, 2013 7:51 AM

Page 1530 of 2169

02854

To: Fein; Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman; Joshua CPT USARMY
Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard; Angel CPT
USARMY Whyte; Hunter CPT USARMY von Elten; Alexander (Alec)
CPT USARMY (usx? USARMY (usx- -
CIV (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Ashden;
Thank you.

Best;
David

David E. Coombs; Esq.

Law Of?ce 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



Notice: This transmission; including attachments; may
contain con?dential attomey-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 prohibited.



From: Fein; Ashden MAJ USARMY MDW

Sent: Monday; January 14; 2013 8:41 AM

To, CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

All

7

A teleconference bridge is reserved starting at 1500 today. The dial-in
instructions are:



Note: When you dial; you will be asked to input this PASSCODE: -
Afterwards; dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

v/r

Page 1531 of2169

02855

MAJ Fein



From: - -F cw
Sent: Friday, January 11; 6 3 4:40 PM

To: Fein; Ashden MAJ USARMY MDW (US)

Cc: David Coombs; Hurley, Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

MAJ Fein;

Yes; I am available at 1500 EST (1400 CST), Monday January 14th. For the
remainder of the week; I am available Tuesday through Friday 0800--l600 EST
(0700--1500 CST).

Re gards,

5

Center for Army Lessons Learned
://usacac.arm mil/cac2/call/



US. Army Combined Arms Center
Fort Leavenworth; KS. 66027




From: Fein; Ashden MAJ USARMY MDW (US)
Sent: Friday; January 11; 2013 2:58 PM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman; Joshua CPT
USARMY Morrow; JoDean (Joe) CPT USARMY USAMDW Overgaard;
Angel CPT USARMY Whyte; Hunter CPT USARMY von Elten;

Alexander (Alec) CPT USARMY USARMY (US)

Subject: Teleconference
Importance: High

Mr.-

Thank you for the phone conversation. Are you available on Monday at 15 00
EST for a conference call between defense counsel (Mr. Coombs) and the
government prosecutors?

v/r

Page 1532 of 2169

02856

MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1533 of 2169

02857

From: Fein, Ashden MAJ USARMY MDW (US)
To: vi
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY USARMY
Overgaard, Angel CPT USARMY Tooman, Joshua CPT USARMY (US)

Bcc:
Mitroka Katherine

CPT USARMY (US)







Subject: RE: Mail
Date: Monday, January 21, 2013 11:31:00 AM
David,

Thank you. We will start looking into this.

v/r

Ashden



From: David Coombs [mailtozcoombs arm c0urtmartialdefense.c0m]

Sent: Friday, January 18, 2013 2:09 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte,
Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY

USARMY Overgaard, Angel CPT USARMY Tooman, Joshua CPT USARMY (US)

Subject: Mail

Ashden,

The JRCF is now forwarding mail to Howard County. Given the volume of mail,
it may be better for them to forward it to the unit to avoid any security
concerns.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



*Con?dentiality Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1534 of 2169

02858

From: David Coombs
To: in A MA ARMY MDW
Cc: Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter

CPT USARMY von Elten, Alexander (Alec) CPT USARMY
Overgaard, Angel CPT USARMY Tooman, Joshua CPT USARMY (US)

USARMY



Subject: Mail
Date: Friday, January 18, 2013 2:10:27 PM
Ashden,

The JRCF is now forwarding mail to Howard County. Given the volume of mail,

it may be better for them to forward it to the unit to avoid any security
concerns.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential 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 prohibited.

Page 1535 of 2169

02859



From: Tooman, Joshua CPT USARMY (US)

To: Fain, Ashden MAJ LJSARMY MDW Morrow, ,JQDgan (Joe) QPT LJSARMY LJSAMDW Qvergaard, Angel
QPT LJSARMY Whng, ,1 HunIgr QPT LJSARMY Algxandgr (Algg) QPT LJSARMY (LJS)

Cc: Hurley, Thomas MAJ USARMY Hall, Cassius CIV (US)

Subject: Forensics

Date: Friday, January 18, 2013 1:04:24 PM

Sir

We plan to have our forensics guys do a review of the remaining evidence at the end of this month. Does any of that
evidence require the presence of Mr. Prather?

Thanks,

Josh

Page 1536 of 2169

02860



From: Tooman, Joshua CPT USARMY (US)

To: Qvergaard, Angel USARMY in A MA ARMY MDW

Cc: "David Coombs"; Hurley, Thomas MAJ USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW
Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Witness Issues (UNCLASSIFIED)

Date: Friday, January 18, 2013 12:38:55 PM

Angel

Do you have email contact info for these witnesses?

The phone number for Mr. TraVieso rings to a? voicemail and I'd prefer to not leave a message on a
system that may or may not be accessible by the witness.

The number for LT Hoskins does not have voicemail. I am, thus, at the mercy of whether or not he picks up an
unknown number.

Thanks,

Josh



From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 14, 2013 10:06 AM

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

Cc: 'David Coombs'; Hurley, Thomas MAJ USARMY Morrow, oDean (Joe) CPT USARMY

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

Subject: RE: Witness Issues (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED

Caveats: NONE

Josh,

Mr. TraVieso's number_ is c0rrect--I con?rmed on Friday.

LT Hoskin's cell phone number is?

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW



Page 1537 of 2169

02861

From: Fein, Ashden MAJ USARMY MDW (US)

Sent: Monday, January 07, 2013 9: 17 PM

To: Tooman, Joshua CPT USARMY (US)

Cc: 'David Coombs'; Hurley, Thomas MAJ USARMY Morrow, oDean (Joe) CPT USARMY

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

Subject: RE: Witness Issues

Josh,
We will work this week to get you the most updated contact info for those two witnesses.

v/r

MAJ Fein



From: Tooman, Joshua CPT USARMY (US)

Sent: Monday, January 07, 2013 5:12 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: 'David Coombs'; Hurley, Thomas MAJ USARMY Morrow, oDean (Joe) CPT USARMY

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

Subject: Witness Issues

Sir

Do you all have updated or alternative contact information for the following individuals:

LT Thomas Hoskins: No voicemail

Ms. Louis Travieso: Wrong number

Thanks,

Josh

Classi?cation: UNCLASSIFIED
Caveats: NONE

Page 1538 of 2169

02862



From: Hurley, Thomas MAJ USARMY (US)

To: in A MA ARMY MDW Morrow, ,Jngan (dog) QPT LJSARMY LJSAMDW (L15)
Cc: Tooman, Joshua CPT USARMY

Subject: Witnesses

Date: Friday, January 18, 2013 12:00:19 PM

Gents

There are some problems with the following witnesses:

#82 (MG Kenneth McKenzie) - contact info is bad. I sent him an email through my outlook directly, but I don't
know if it's going to get to him or what he is going to do with it.

#119? - didn't know anything about being a witness. Gave her MAJ Fein's name and number.

#127 - no record of him in DC or Houston. (I don't know why the receptionist transferred
me to Houstonavail.)

(I've only been able to leave messages withFand- so I don't know if any of these four are aware that
you are calling them as witnesses.) 6

Please help as soon as you can. For non-?ag of?cers, it may help to give me their email. I ?nd that's the best way
to contact someone. (People ignore voicemails like you wouldn't believe.)

Thanks.

MAJ Hurley

Page 1539 of 2169

02863

From: David Coombs
To: vr An IM PT ARMY
Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY Morrow, JoDean (Joe) CPT

USARMY USAMDW Whyte, Hunter CPT USARMY von Elten, Alexander (Alec) CPT USARMY
USARMY Fein, Ashden MAJ USARMY MDW (US)



Subject: RE: Teleconference (UNCLASSIFIED)
Date: Friday, January 18, 2013 10:56:53 AM
Angel,

Just let me know once you have the dates. On a side note, can you send me
copies of COL Lind's rulings from our last session? Thank you.

Best,
David

David E. Coombs, Esq.

Law Of?ce 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



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.


From: Overgaard, Angel CPT USARMY (US)

Sent: Thursday, January 17, 2013 2:34 PM

To. 1% CW (US)

Cc: Hurley, Thomas USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY

USARMY 'David Coombs'; Fein, Ashden MAJ USARMY MDW (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
Mr. - and I spoke today and agreed to reschedule for next week. He
will

send out his availability either this week or early next week. Then, we can
agree on a time for a teleconference that works for all of us after Monday.
Thank you.

Page 1540 of 2169

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW



From: - - cw
Sent: Wednesday, Janua 2013 8:51 AM

To: Overgaard, Angel CPT USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

CPT Angel Overgaard,

I am available Thursday from 0900--1200 EST. l400--l600 EST.
I am available Friday from ll30--l600 EST.

Monday is a Federal Holiday, Martin Luther King Jr. Day.
Regards,

Center for Army Lessons Learned
http://usacacarmy mil/cac2/call/

US. Army Combined Arms Center
Fort Leavenworth, KS. 66027





From: Overgaard, Angel CPT USARMY (US)

Sent: Monday, January 14, 2013 3:58 PM

To: - - CIV David Coombs; Fein, Ashden MAJ USARMY
MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Whyte, Hunter CPT USARMY
von Elten, Alexander (Alec) CPT USARMY
USARMY (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

Mr.-

Please let us know what times work for you this week. We are in court
Wednesday and Thursday, but we could possibly schedule something during the

Page 1541 of2169

02864

02865

lunch hour. Thank you!

VR

ANGEL M. OVERGAARD
CPT, JA

Trial Counsel, MDW



From: - - cw (Us
Sent: Monday, January l4 13 2:38 PM

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

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY

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

Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

All,
I am sorry, I am taking leave for the rest of the day, Monday Jan 14. I
will not be available for today's teleconference.

Request we postpone this meeting for later this week. I am sorry for the
delay.
I will be back in the of?ce Tuesday January 15th.

Regards,

5



From: David Coombs [mailtozcoombs arm courtmartialdefense.com]

Sent: Monday, January 14, 2013 7:51 AM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: Hurley, Thomas MAJ USARMY Tooman, Joshua CPT USARMY
Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard, Angel CPT
USARMY Whyte, Hunter CPT USARMY von Elten, Alexander (Alec)
CPT USARMY (usx? USARMY (usx- -
CIV (US)

Subject: RE: Teleconference (UNCLASSIFIED)

Ashden,
Thank you.

Best,
David

David E. Coombs, Esq.

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

Page 1542 of 2169

02866

Toll Free: 1-800-588-4156

Local: (508) 689-4616

Fax: (508) 689-9282



Notice: This transmission, including attachments, may
contain con?dential attomey-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 prohibited.



From: Fein, Ashden MAJ USARMY MDW

Sent: Monday, January 14, 2013 8:41 AM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

All

7

A teleconference bridge is reserved starting at 1500 today. The dial-in
instructions are:



Note: When you dial, you will be asked to input this PASSCODE
Afterwards, dial the key to join the conference call. The line will be
ready 5 minutes prior to start of teleconference.

v/r
MAJ Fein



From: - cw am
Sent: Friday, January 11, 3 4:40 PM

To: Fein, Ashden MAJ USARMY MDW (US)

Cc: David Coombs; Hurley, Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,
Alexander (Alec) CPT USARMY USARMY (US)
Subject: RE: Teleconference (UNCLASSIFIED)

Classi?cation: UNCLASSIFIED
Caveats: NONE

MAJ Fein,

Yes, I am available at 1500 EST (1400 CST), Monday January 14th. For the
remainder of the week, I am available Tuesday through Friday 0800--l600 EST

Page 1543 of 2169

02867

(0700--1500 CST).

Regards,



Center for Army Lessons Learned
://usacac.arm mil/cac2/call/



US. Army Combined Arms Center
Fort Leavenworth, KS. 66027




From: Fein, Ashden MAJ USARMY MDW (US)
Sent: Friday, January 11, 2013 2:58 PM

To. CIV (US)

Cc: David Coombs; Hu Thomas MAJ USARMY Tooman, Joshua CPT
USARMY Morrow, JoDean (Joe) CPT USARMY USAMDW Overgaard,
Angel CPT USARMY Whyte, Hunter CPT USARMY von Elten,

Alexander (Alec) CPT USARMY USARMY (US)

Subject: Teleconference
Importance: High

Mr.-

Thank you for the phone conversation. Are you available on Monday at 1500
EST for a conference call between defense counsel (Mr. Coombs) and the
government prosecutors?

v/r
MAJ Fein

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED
Caveats: NONE

Classi?cation: UNCLASSIFIED

Page 1544 of 2169

02868

Caveats: NONE

Page 1545 of 2169

02869



From: Hurley, Thomas MAJ OSD OMC Defense

To: rr"

Cc: HoldenI Paul Jr CIV FeinI Ashden MAJ USARMY MDW (US)
Subject: RE: Defense Counsel Interview

Date: Friday, January 18, 2013 8:31 :22 AM

Sir,

Your accounting of our phone conversation is accurate. I have copied MAJ Fein, the lead prosecutor, to help us
understand what classi?ed information can be discussed in our interview and what, if any, will be the substance of
your testimony at trial. The defense has been told that you will discuss classi?ed information.

On location - I have a conference room just outside my of?ce that is available for our meeting. But I have no
problem going to DIA if that would be easier.

Look forward to meeting you in a week.

v/r
MAJ Hurley


From: Rob Carr
Sent: Thursday, January 17, 2013 5:01 PM
To: Hurley, Thomas MAJ OSD OMC Defense
Cc: Holden Jr, Paul P.
Subject: Defense Counsel Interview
MAJ Hurley,
Per phone conversation.
This is a good e-mail address for me.
Ihave blocked 0900 - 1030, Friday, 25 Jan 13.
Will stand by for clari?cation on a location albeit, looking at or Bolling AFB at this time.

And need a determination on the Classi?cation level for the discussion.

RAC

Page 1546 of 2169

02870



From: Hurley, Thomas MAJ OSD OMC Defense

To: IV

Cc: Fein, Ashden MAJ USARMY MDW Lewenhaugt, Claes
Subject: RE: Interviews of DIA Personnel

Date: Thursday, January 17, 2013 3:20:15 PM

Mr. Holden

Thanks!

MAJ Hurley



From: Holden Jr, Paul P.

Sent: Thursday, January 17, 2013 2:59 PM

To: Hurley, Thomas MAJ OSD OMC Defense

Cc: 'Fein, Ashden MAJ USARMY MDW Lewenhaupt, Claes
Subject: RE: Interviews of DIA Personnel

As of two days ago, BG Carr told me that no one from the defense team has attempted to contact him.

Please exercise due diligence to reach BG Carr using the witness contact information provided by the SJA of?ce. If
you are unsuccessful, I will endeavor to assist.

PH

Paul P. Holden, Jr.

Assistant General Counsel
Defense Intelligence Agency
Washington, DC 20340



From: Hurley, Thomas MAJ OSD OMC Defense?

Sent: Thursday, January 17, 2013 2:38 PM
To: Holden Jr, Paul P.
Subject: Interviews of DIA Personnel

Mr. Holden

I am a criminal defense attorney representing PFC Bradley Manning. I have been given your name as a POC for
interviewing BG (Retired) Carr.

I would like to schedule the interview as soon as possible.
Thanks.

MAJ Hurley

Page 1547 of 2169

02871



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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