Title: Def Discovery Req, 1 Aug 12

Release Date: 2014-03-20

Text: UNITED STATES OF AMERICAv.Manning, Bradley E.PFC, U.S. Army,HHC, U.S. Army Garrison,Joint Base Myer-Henderson HallFort Myer, Virginia 22211Prosecution Responseto Defense Motion toCompel DiscoveryEnclosure 223 August 2012UNITED STATESDEFENSE DISCOVERYV- REQUESTMANNING, Bradley E., PFCU.S. Anny,Headquarters and Headquarters Company, U.S.Anny Garrison, Joint Base Myer-Henderson Hall,Fort Myer, VA 2221 IDATED: I August 20121. In accordance with the Rules for Courts-Martial 70l(a)(2), 701 and the Military Rulesof Evidence, Manual for Courts-Martial, United States, 2008, Article 46, Uniform Code ofMilitary Justice, and other applicable law, request for discovery is hereby made for the chargedoffenses in the case of United States v. Bradley E. Manning.2. PFC Manning was held at Marine Corps Base Quantico from 29 July 20l0 to 20 April 20! l.During this time, he was held in Maximum Custody (MAX) and under Prevention of Injury(POI) watch.3. On 8 December 20l0, the Defense made a discovery request for all documentation fromQuantico pertaining to PFC Manning. The Government provided extensive documentationrelated to PFC Manning?s con?nement at Quantico in October of 20l I. The Defense believedthat this was the full extent of the infonnation the Government had from Quantico.4. On 26 August 20I2, the Government produced 84 emails from various individuals. TheGovernment indicated that these emails were ?obviously? material to the preparation of thedefense for the Article I3 purposes. MAJ Fein indicated that the Government received theseemails from Quantico approximately 6 months ago. However, the Government did not beginreviewing the emails until 25 July 2012.5. On 3| August 20l2, CPT Joe Morrow, by e-mail, infonned the Defense that the Governmenthad ?made a generalized request for Quantico to gather and preserve documents and informationpertaining to PFC Manning?s confinement." CPT Morrow stated that ?they responded byproviding documents and information pertaining to his con?nement, and included some emails.?6. The Defense requests that the Government provide the following discovery:a) The memorandum/e-mail/document from the Government to Quantico requesting thatthey preservation and produce documents and information pertaining to PFC Manning?scon?nement;b) The names of the individuals who the Government sent the Quantico preservation requestto and the date which the Govemment made its request;Defense Discovery Request PFC Bradley E. Manning0)d)All documentation provided by these individuals in response to the Government?srequest, the date this information was provided, and the individuals who provided therequested information; andAny other e-mails or documentation that the (?iovemment is aware of and has notpreviously provided to the Defense dealing with Manning?s confinement conditionswhile at Quantico.7. The Defense also requests any e-mails or documentation relating to PFC Manning or Manning?s con?nement conditions from or to the following specifically listed individualsGeorge J. Commanding General, 3300 RussellRoad Building:' 3300 Floor: 2 Room, Quarters I /Command Suite. Quantico, VA 22|34.Col. Christopher Miner, StaffJudge Advocate, 3300Russell Road Building 3300 Floor 2, Room 227, Quantico, VA 22l34 Col. Royal Mortenson, Chiefof Staff, 3300 Russell RoadBuilding: 3300 Floor: 2 Room: 224, Quantico, VA 22l34. COL Carl R. Coffman . 205B Lee Avenue, Joint BaseMyer-Henderson Hall, Virginia 222l I. Col. Daniel J. Choike, I, Base Commander, 3250 Catlin Ave.,Building 3250, Floor 2, RoomCube Suite, Quantico, VA 22134.?Col. Mark M. Kauzlaric Chiefof Staff, 3250 Catlin Ave.,Building 3250, Floor B, Room 28, Quantico, VA 22134 CDR Han Bui,?l, Building IA Floor 2, Room 9, l\'orfolk, VA235" Capt. Mary Neill. l.tCol. Christopher M. Greer, StaffJudge Advocate,Building: l0l9, Floor: l, Room: SJA, Quantico, VA 22l34l.tCol. Amy R. libitz, Executive Officer, 2043 Baranett Ave,Quantico, VA 22|34 .John Haberland, Regimental Judge Advocate,20lJackson Ave, Fort Myer, VA 22003.?CWO5 Abel Galaviz . Building Pentagon, Floor 4, Room/Cube4A324, Washington D.C., 20380-I775.Defense Discovery Request PFC Bradley F.. Manningm) CWO4 James T. Averhart S-3 Officer, 2043 Baranett Ave,Quantico, VA 22l34P)(I) CWO2 Denise Barnes, Brig Executive Officer, Camp HansenBldg: Floor I, Room I07, PFO, APBrian R. Papakic, Brig Supervisor, 3247 Elrod AveBuilding: 3247 Floor I, Room :10, Quantico, VA 22134-(}ySgt Craig M. Blenis I, Sergeant Instructor, 2| 89 Elrod AveBuilding 5001, Floor 1, Room I, Quantico, VA 22134 andWilliam R. Fuller, 56|, Building 608, Floor, IRoom/Cube 2| I, FPO, AP. .8. The Defense requests that the Government provide notice in writing as soon as possible if itdoes not intend to comply with any speci?c provision ofthis request. The Defense will needtimely notice ofthe Government?s intent to not comply in order to immediately ?le a motion tocompel discovery. Timely notice by the Government will avoid the need for an additional delayfor the Article I3 motion.9. It is understood that this is a continuing request.I0. A copy ofthis request was served on Trial Counsel by e-mail on I August 2012.DAVID EDWARD COOMBSCivilian Defense Counsel

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