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Update (UNCLASSIFIED)



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


Attachment: Motion to Compel Verbatim Transcript.docx
Description: Motion to Compel Verbatim Transcript.docx