Gentlemen: Here are the assignments I made for division of labor regarding witness examinations. We each have approximately 8 witnesses. If you want to swap witnesses for some reason no sweat. For the most part I divided them based on prior interviews we have each done. -----Original Message----- From: Baehr Capt James S Sent: Monday, April 11, 2011 14:41 To: Haytham Faraj; Workman Maj Adam J Cc: Ted card Subject: RE: Witness interviews Gentlemen, Here is the Marco Jimenez interview. He has not had a chance to see his statement yet. He does not remember the situation well (didn't remember it at all until NCIS brought it up), and he says his perception was impacted by the position of the C2 in front of him and the knee high grass. But he remembers seeing out of his peripheral vision Capt Card shooting what he is 100% sure was an insurgent in the field. He remembers NCIS grilling him for 3-4 hours, not letting him go, because he wasn't "giving them what they need." He does not understand why he has to participate in this and does not want to be used by the prosecution. Maj Goode is going to go interview him in San Diego on Wednesday with his statement. He spoke to her 6 months ago otherwise and her questions revolved around whether the Iraqi appeared to be a threat or was a civilian. He believes he was a threat. R/s, Jim -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Thursday, February 17, 2011 13:05 To: Workman Maj Adam J; Baehr Capt James S Cc: Ted card Subject: Witness interviews Gentlemen, Here are the first witnesses I'd like to speak to with along with their contact information. Please let them tell you their stories but don't forget to allow them to tell you about NCIS interview. This shouldn't be a cross examination. Even if they have negative to say, it's important that we respect what they have to say. If they need to be shredded we can do it at the 32. Let's try to get these guys done by COB tomorrow. Andrew Tipton: 661-831-2805. Workman Christopher Russell: 909-561-3626. Workman HM1 Slaughter: 505-331-1603. Workman Marco Jimenez: 760-580-0684. Baehr 1stSgt Beall: 725-0314. Baehr Carlos Guttierrez: 760-547-356 Faraj Andrew Wike: 402-214-5008. Faraj Jackie Phillips: 949-338-7996. Faraj Vr, Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC P.O. Box 1016 Dearborn Heights, MI 48127 313-457-1390 Phone 202-280-1039 Fax www.puckettfaraj.com <http://www.puckettfaraj.com/> 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 888-970-0005 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.
Attachment:
US v Maj Card - Art32 Witnesses.docx
Description: application/vnd.openxmlformats-officedocument.wordprocessingml.document
Attachment:
smime.p7s
Description: S/MIME cryptographic signature