Haytham,
Today, we sent via Fedex a CD with discovery materials to your Alexandria office.
Also, in thinking about how the trial will play out, we wanted to let you know that we are not planning to raise or introduce evidence of other instances of possible falsifications in ROI’s by Davila (and thus have not provided discovery on other possible
falsifications), unless you plan to try to argue that the charged falsifications were his only falsifications and that he truthfully reported all of his other work (to which we would object). If you plan to make such an argument, please let us know, so that
we can discuss how to proceed.
Sincerely,
Mary Chris Dobbie, AUSA
Fraud & Public Corruption Section
555 4th St., N.W., Room 5437
Washington, D.C. 20530
Tel. 202-252-6975
Fax 202-307-2304
Cell 202-468-8073