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Re: Update



Perfect!  Got the news that Keefe was acquitted.  Let's use the doc, and forego Cimino.  All of your recommendations are approved.
We have a UCI motion coming, too, based on an interview on FOX with Geraldo Rivera on O'Reilly Factor.  Haytham penning a letter to Cleveland telling him of polygraph, UCI evidence and two acquittals, suggesting that proceeding on McCabe would be additional evidence of UCI.  There was a suggestion that Cleveland had no choice, perhaps from higher up, after Rivera interviewed Cleveland or someone on his staff.  We have the transcript.  Let's talk when you get in.  I'll come down next week to help.
Neal
Neal A. Puckett, Esq
LtCol, USMC (Ret)
Puckett & Faraj, PC
Washington DC Metro Area
888.970.0005

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On Apr 23, 2010, at 3:08 PM, Kevin Shea wrote:

Some more great news with Keefe!   

Neal, I put in the witness production request.  I don't know how you want to handle this, but if we are forced into the one-for-one deal, I'd suggest that we notify the government that we do not need MA2 Cimmino produced (he is not a good witness - he got relieved by MA3 Demartino, who then supervised him + nice guy, but doesn't come across well) if they can accomplish the production of LTjg Heise - a solid witness.  Also, there was an oral surgeon called in the Huertas case -  Capt Curtis Schmidt, US Army, stationed here on the Victory Base Complex and available by phone at DSN 318 446 2615 (clinic), 446 3500 (ER, avail 24/7), 446 6448 (quarters) who was very helpful there.  I spoke today with a member in the Huertas case and he was impacted by the surgeon's ability to offer that the injuries in question are consistent with intention biting, and not with serious trauma (although could be consistent with a fall if the body absorbed the brunt of the fall).  Telephonic testimony is a possibility and can be accomplished without much trouble, as I believe we can call DSN from the courtroom. 

We'll be back in the office late Monday.  Kristen's working up notes tonight and we'll have a draft of witness order in the next 2 days.  

-Kevin