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RE: Defense supplemental voir dire



Counsel,

As I told you after Court, the government may not change the 134 charges.  It is a major change.  

As far as the government amending the Article 119 charges, that is permissible.  I have read the case law and am allowing the change.  The defense has been properly put on notice as is clear from the very wording of the specification, to include the word "believed to be".  The remaining language and substituting "unknown person" is legally sufficient and protects the accused against double jeopardy.  The Court sees no surprise or confusion on the part of the defense.  The bodies were clearly marked with the BDA.

R,

LtCol Jones

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Wednesday, January 04, 2012 7:05
To: Jones LtCol David M
Cc: Sullivan LtCol Sean; Gannon Maj Nicholas L; Marshall Maj Meridith L; neal@puckettfaraj.com
Subject: Defense supplemental voir dire

Good morning your Honor,
The defense submits and respectfully requests the attached supplemental voir dire.



Vr,

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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703-706-0442 Phone
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The Law Firm of Puckett & Faraj, PC
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www.puckettfaraj.com

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