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RE: Saleh Issues (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Trial Counsel
Response?
Mr. Faraj
Have you called the witness to discuss her potential testimony?
COL Pohl
-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Thursday, August 25, 2011 10:27 AM
To: Pohl, James L COL MIL USA; Wardlow, Russell D CPT MIL US USA FORSCOM
Cc: Wright, Matthew E CPT MIL US USA FORSCOM; Douglas, Laquisha S CPT MIL USA FORSCOM
Subject: RE: Saleh Issues (UNCLASSIFIED)
In receipt.
Your honor, I think there is another issue that we may need to address. I believe the Government may call an expert witness, psychologist. We have not been provided any of the information pursuant to R.C.M. 703(d) and Giglio. To the best of my knowledge we have only received a CV. If the government intends to call her as a witness and not just use her as an expert consultant, I will object to the witness being permitted to testify because we have not been provided the required disclosures prior to her being retained, as required by the Rule.
Vrs,
Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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-----Original Message-----
From: Pohl, James L COL MIL USA [mailto:james.pohl@us.army.mil]
Sent: Thursday, August 25, 2011 9:43 AM
To: Wardlow, Russell D CPT MIL US USA FORSCOM
Cc: Wright, Matthew E CPT MIL US USA FORSCOM; haytham@puckettfaraj.com; Douglas, Laquisha S CPT MIL USA FORSCOM
Subject: Saleh Issues (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
All
At the 39a on Monday, I think we have the following to discuss:
The impact of Fosler on Charge III.
The 404b notice, dated 29 Jul 11.
TC motion in limine, dated 13 Jun 11.
Self authentication of phone records, dated 29 Jul 11.
Then, we will take formal entry of forum and plea and discuss voir dire.
Each side needs to bring signed, original copies of any document you want to make part of the records. Documents sent to me will not be inserted in the record.
Have I missed anything? Questions?
COL Pohl
Classification: UNCLASSIFIED
Caveats: NONE
Classification: UNCLASSIFIED
Caveats: NONE