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RE: Update (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: FOUO
Okay. I will hold off on submitting the motion today, and find out if
they will agree to waive the objection. The civilian paralegal is only
doing Houda's testimony. Is that okay with you?
-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Friday, July 22, 2011 9:28 AM
To: Douglas, Laquisha S CPT MIL USA FORSCOM
Subject: Re: Update (UNCLASSIFIED)
I'm overseas. I think having the paralegal do it and asking the
government to wave objections is reasonable. What I do in civilian
practice is call the government and ask them to wave authentication
objection. If they don't, I state so in the motion and ask the court to
either pay for a court reporter or pre admit over government objection.
Haytham Faraj
Sent from my iPad
On Jul 21, 2011, at 9:06 PM, "Douglas, Laquisha S CPT MIL USA FORSCOM"
<laquisha.douglas@us.army.mil> wrote:
> Classification: UNCLASSIFIED
> Caveats: FOUO
>
> Mr. Faraj,
>
> Attached is the motion to compel the verbatim transcript. I plan on
> filing it tomorrow, but I wanted to speak to you about it first. I
> have found one of the secretaries from Legal Assistance who is willing
> to transcribe Houda's testimony for us because she has nothing else
> better to do over there. I need to make sure that is okay with her
> supervisor first, but I wanted to know if that made a difference to
> you as far as the motion to compel goes.
>
> My supervisor suggested having the secretary transcribe it and see if
> the Government would be amenable to pre-admitting it as an exhibit. If
> they have an authentication objection, then we could file motion to
> pre-admit it using the Government's denial for our verbatim transcript
> request as a basis. Either way is fine with me, I just wanted to bring
> that to your attention.
>
> I will also submit the witness production request tomorrow. We cut one
> or two people who did not want to testify. They all have had initial
> interviews. I suspect that the government is going to refuse to
> produce some of the family members (Saleh's mom, stepdad, sister,
> brother are all on the list) unless they have something very unique to
say.
>
> I will Cc you on everything tomorrow and give you a call.
>
> Thanks,
>
>
> CPT Laquisha Douglas
> Defense Counsel
> Fort Irwin Field Office
> U.S. Army Trial Defense Service
> P: 760-380-4199
> F: 760-380-5901
>
>
> Classification: UNCLASSIFIED
> Caveats: FOUO
>
>
> <Motion to Compel Verbatim Transcript.docx>
Classification: UNCLASSIFIED
Caveats: FOUO