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