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RE: Lopez witness interviews



Haytham,

I'm getting on it now.  I am definitely available tomorrow morning.  I'll see you then.

V/r,


Bret A. White
Captain, U.S. Marine Corps
Defense Counsel

Office of the Staff Judge Advocate
Marine Corps Base               
3250 Catlin Avenue                            
Quantico, VA 22134                           

Main:    703.784.4615/4628
Direct:  703.784.0405
Fax:     703.784.0259




-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Tuesday, May 10, 2011 8:13
To: White Capt Bret A
Subject: Lopez witness interviews

Good morning Bret,

Please submit a request to have GySgt Kelton produced as a witness.  We need that request sent out immediately so we can work through the issue of testimonial immunity.  GySgt Kelton is a necessary, relevant and material witness.  She is an exculpatory witness to several of the charges on the charges sheet.  I have been informed by her counsel that she has testimony that directly contradicts the charged offenses.  He would not go into any great detail but shared facts about one charge, the taking of photos of candidates.  He told me that Kelton specifically rebuts that.  I believe that there will be a lot more.  

Also please prepare and submit a simple witness production motion for all witnesses that you believe are relevant but that the Government denied.  Do not go into great detail on the law.  The judge knows the law. Provide the facts necessary to show why the witnesses are relevant and necessary to persuade the judge.  Let me know if you?re available tomorrow morning.

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

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