Got it. In that case we need to file a notice of appearance for Mr. Haytham with the military judge. /r RANAE L. DOSER-PASCUAL, Capt, USAF Area Defense Counsel Dyess AFB, TX (325) 696-4233 (DSN 461) CONFIDENTIALITY NOTICE. This electronic transmission may contain attorney work-product or information protected under the attorney-client privilege, or other such information exempt from disclosure under applicable laws,including, but not limited to, the FOIA, Privacy Act, 5 USC 552, or Military Rules of Evidence. Any use, distribution, copying or other disclosure by any other person is strictly prohibited. If you have received this transmission in error, please notify the sender at the number or e-mail address above. Do not release outside of DoD channels without prior authorization from the sender. This e-mail may contain FOR OFFICIAL USE ONLY (FOUO) information which must be protected under the Privacy Act and AFI 33-332. -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Friday, July 08, 2011 9:19 AM To: Doser-Pascual, Ranae L Capt USAF AFLOA AFLOA/ADC Cc: Faraj Haytham Subject: Re: case status Got it. But we are just now "alerted" to the issue based on a government ordered exam. Plus, and I forgot to mention, Haytham is joining the team and he's not available in August, either. Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com www.twitter.com/puckettfaraj The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 703-706-9566 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jul 8, 2011, at 10:16 AM, Doser-Pascual, Ranae L Capt USAF AFLOA AFLOA/ADC wrote: Neal, Completely agree; my only concern is that since we haven't officially requested him yet, that when we do, and if he is not available for the trial date, the NAF says "not going to approve your specific request but we've found an alternate forensic psych that is available for you on the scheduled trial date - here you go." /r RANAE L. DOSER-PASCUAL, Capt, USAF Area Defense Counsel Dyess AFB, TX (325) 696-4233 (DSN 461) CONFIDENTIALITY NOTICE. This electronic transmission may contain attorney work-product or information protected under the attorney-client privilege, or other such information exempt from disclosure under applicable laws,including, but not limited to, the FOIA, Privacy Act, 5 USC 552, or Military Rules of Evidence. Any use, distribution, copying or other disclosure by any other person is strictly prohibited. If you have received this transmission in error, please notify the sender at the number or e-mail address above. Do not release outside of DoD channels without prior authorization from the sender. This e-mail may contain FOR OFFICIAL USE ONLY (FOUO) information which must be protected under the Privacy Act and AFI 33-332. -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Friday, July 08, 2011 9:08 AM To: Doser-Pascual, Ranae L Capt USAF AFLOA AFLOA/ADC Cc: Faraj Haytham Subject: Re: case status Ranae, Good to know. We'll grab the civilians if we need to. But this is one of those cases where; since the weight of the psych evidence is already firmly in our corner, it almost screams to have someone in uniform deliver the opinions to rob the TC of the argument that we bought the opinion we wanted from our hand-picked private doc. How does the government impeach the opinion of a military forensic psychiatrist who is echoing the opinions of 3 other military shrinks? Of course they're still going to get the "voluntary intox" instruction. And although it will rationalize the decision to refuse to dismiss charges before trial, it won't ultimately get them anywhere. Because their logic will have to be, he is responsible for voluntarily intoxicating himself into a condition where he was no longer responsible for his conduct. Huh? Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com www.twitter.com/puckettfaraj The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 703-706-9566 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jul 8, 2011, at 9:29 AM, Doser-Pascual, Ranae L Capt USAF AFLOA AFLOA/ADC wrote: Neal, My last day here at Dyess is 15 July 11, so I should be in the DC area probably by the 21st. I have a couple different civilian forensic psych's that I've worked with on various types of cases if we need to request one and Dr. Benedek isn't available. /r RANAE L. DOSER-PASCUAL, Capt, USAF Area Defense Counsel Dyess AFB, TX (325) 696-4233 (DSN 461) CONFIDENTIALITY NOTICE. This electronic transmission may contain attorney work-product or information protected under the attorney-client privilege, or other such information exempt from disclosure under applicable laws,including, but not limited to, the FOIA, Privacy Act, 5 USC 552, or Military Rules of Evidence. Any use, distribution, copying or other disclosure by any other person is strictly prohibited. If you have received this transmission in error, please notify the sender at the number or e-mail address above. Do not release outside of DoD channels without prior authorization from the sender. This e-mail may contain FOR OFFICIAL USE ONLY (FOUO) information which must be protected under the Privacy Act and AFI 33-332. -----Original Message----- From: Puckett Neal [mailto:neal@puckettfaraj.com] Sent: Friday, July 08, 2011 8:22 AM To: Doser-Pascual, Ranae L Capt USAF AFLOA AFLOA/ADC Cc: Faraj Haytham Subject: Re: case status Ranae, Yes, as we're still trying to get Dr. Benedek (forensic psych) to agree to be requested. He's tough to pin down. He expressed interest and agreed to further research, but we haven't discussed his schedule yet. My conversation with Kouba was simply to alert him to the fact that we may need to begin a search for such an expert and thus may need more time. He acknowledged that it may be required and said they may need to search for an expert, as well. Kinda funny since they'd be searching for someone to rebut their own, CA-appointed experts who reached a conclusion they don't like. But we would never make any commitments without coordinating with your schedule, of course. Any word one when they're going to release you to PCS? Neal Neal A. Puckett, Esq LtCol, USMC (Ret) Puckett & Faraj, PC 1800 Diagonal Rd, Suite 210 Alexandria, VA 22314 703.706.9566 www.puckettfaraj.com www.twitter.com/puckettfaraj The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 703-706-9566 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. On Jul 7, 2011, at 3:09 PM, Doser-Pascual, Ranae L Capt USAF AFLOA AFLOA/ADC wrote: Neal, I talked to Capt Kouba today and he mentioned you two spoke yesterday and you indicated the defense may have to ask for a delay. Is this true? /r RANAE L. DOSER-PASCUAL, Capt, USAF Area Defense Counsel Dyess AFB, TX (325) 696-4233 (DSN 461) CONFIDENTIALITY NOTICE. This electronic transmission may contain attorney work-product or information protected under the attorney-client privilege, or other such information exempt from disclosure under applicable laws,including, but not limited to, the FOIA, Privacy Act, 5 USC 552, or Military Rules of Evidence. Any use, distribution, copying or other disclosure by any other person is strictly prohibited. If you have received this transmission in error, please notify the sender at the number or e-mail address above. Do not release outside of DoD channels without prior authorization from the sender. This e-mail may contain FOR OFFICIAL USE ONLY (FOUO) information which must be protected under the Privacy Act and AFI 33-332.
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