Re: Draft 1 of response

[Ibrahim Al-Marashi <ibrahim.almarashi@gmail.com>]

That is great news Haytham,

A couple of points:

1) If the case can be delayed, I will go to Iraq and return on  May 1.  There I will be able to talk to some Iraq exiles. While I am not sure if they will hand over documents to me, it could give me some perspectives about how the Iraqi government dealt with Iraqi Americans that that could help with the case.  

2) Ideally, I have a free block of time to come to Michigan from May 3 to May 15.  Otherwise my next block of freetime won´t be until August.  

3) As for Christian Science Monitor documents, they are stored in a safe in the Daily Mirror newspaper.  The Christian Science Monitor sent it to the Mirror and I belive for legal reasons they would not release them, but that was back in 2003.  Maybe they might make them available, or perhaps they sent them back to the CSM. Nevertheless, I did look examine the orignal documents.

4)  I will look over the attachments you sent.  

Thanks,

Ibrahim

On Wed, Mar 17, 2010 at 1:55 PM, Haytham Faraj <haytham@puckettfaraj.com> wrote:

Carolynn,
I've reviewed the motion.  It's a good start.  I don't want you to
specifically refer to the Galloway case.  I want that to be a surprise in
court (see my notes to Ibrahim below).  I am attaching the Sargon
transcripts from Benjamin.  Please review them and pull out what you need.
As you will notice, Sargon is not credible.  He avoids questions and becomes
very defensive.  The issue of administrative versus intelligence files is
very important because like Benjamin we have no intelligence file nor
arguably a full administrative file.  Also pay attention to the testimony
about information card with the oath.  We do not have that either.  All this
brings me to one more issue that I want you to include:  Whether the records
should come in when they are clearly incomplete. Under Rule 106
(completeness) we are entitled to have the entire file.  Anticipate that the
Government will argue that they are not required to produce everything that
is in the possession of the IIS.  That would be true but we are referring to
the entire administrative and intelligence file on a person they claim to be
a spy and whom their own witness states should have both files.  Keep in
mind that their arguing these are authentic documents kept in the normal
course of business.  One of the central basis for admitting business records
is that there is some uniform method for keeping the records.  Accordingly,
if these documents qualify for the business record exception they must be a
part of the larger file to which they belong.

Ibrahim:

1.  Please keep track of your hours on this matter and provide me with
periodic time sheets so we can get you paid.
2.  I have managed to push both the motion and trial to late Spring and
Summer when I assume you will be more free.
3.  I want to use some of the fake IIS documents used against Galloway in my
case.  I intend to present the fake documents to the so called experts the
prosecution is calling to test their ability to identify fakes from
forgeries.  Do you have any of the documents in that case that you can share
with me?
4.  I request that you also review the Sargon transcript and share with me
any thoughts or ideas that his testimony might trigger.

Best to you both,
Haytham

-----Original Message-----
From: Carolynn Beck [mailto:carolynn.beck@gmail.com]
Sent: Tuesday, March 16, 2010 7:39 PM
To: Haytham Faraj
Subject: Re: Draft 1 of response

Ok, sounds good! Have a good night.

Carolynn Beck

On Mar 16, 2010, at 7:04 PM, Haytham Faraj <haytham@puckettfaraj.com>
wrote:

> I'll review it tonight.  We have some scheduling changes. Let's chat
> about it in the morning
>
> Haytham Faraj
> 760-521-7934
> Sent from my iPhone
>
> On Mar 16, 2010, at 4:32 PM, Carolynn Beck <carolynn.beck@gmail.com>
> wrote:
>
>> Hi Haytham,
>>
>> Here's a draft of my response so far. I still need to add some
>> citations for some of the arguments I make based on my discussions
>> with Ibrahim. Please let me know if you know of any sources or have
>> any suggestions. There was some anecdotal knowledge he mentioned
>> that I added to my argument, but he didn't necessarily know of any
>> documents he could point me to. You'll also notice I put brackets
>> in some places where I need to add additional information (like
>> where we need info about Sargon's unreliability). Let me know if
>> you have any criticisms or would like me to add/remove anything.
>>
>> Another thing - I had a hard time matching up some of the
>> Government's exhibits I was comparing with your matrix and our
>> discovery disk from before (mostly everything matched up, but I
>> seem to be missing some of the FBI documents), so please tell me if
>> I need to add more exhibit numbers or take any out that you see
>> where I refer to them directly. (Or, is there a way to just
>> generally refer to all the exhibits to make sure we are covering
>> everything? I referred directly to certain exhibits to give the
>> judge something to refer to, but I'm assuming you will also be
>> referring to the specific exhibits in your oral argument).
>>
>> <CB_RESPONSE_TO_MOTION_TO_ADMIT_DRAFT_1.doc>
>>
>>
>>
>>
>>
>> Carolynn Beck
>> (202) 316-1367
>>
>>
>>

--
Dr. Ibrahim Al-Marashi
Associate Dean of International Relations
Assistant Professor of Communication History & Policy
IE School of Communication, IE University
Campus de Santa Cruz la Real
Cardenal Zúñiga, 12
40003 Segovia, Spain
Mobile +34 663 664 122
Email: ibrahim.almarashi@ie.edu
IE University Website: http://www.ie.edu/university/index.php