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Re: Governments motion to exclude immigration evidence (UNCLASSIFIED)
Classification: UNCLASSIFIED
Mr.Faraj,
I have not received the government's motion. I am on leave until 20 June, so unless they e-mail me directly to my AKO, they would have received an out-of-office reply. CPT Wright has my personal contact information as well, so aside from me being on leave, I don't know why they wouldn't send it to me. Can you forward it to me? I will not have access to Westlaw until I get back to the office.
I submitted a request for a verbatim transcript from the Art 32 and the court reporter is working on it. I did submit a discovery request for Saleh. I believe my paralegal has forwarded you everything we have.
V/R,
Laquisha
On 06/13/11, Haytham Faraj <haytham@puckettfaraj.com> wrote:
> Hi Laquisha,
> I'm sure you read the Government's motion. Please preparer a response. Our theory of admissibility on this evidence is because it gives her a motive to lie in order to remain in the U.S. The second goes to her credibility. When she filled out her initial visa papers she promised not to overstay. She lied which goes to her credibility. Also, have you submitted a discovery request? If not please do so. I also need the transcript from the Article 32 hearing.
>
> Thank you
>
> Haytham Faraj
> Sent from my iPad
Classification: UNCLASSIFIED