If Periard testifies we'll have to keep a short leash on him or he'll turn into one giant alternative to testimony for all of those witnesses he interviewed. -----Original Message----- From: Haytham [mailto:haytham@puckettfaraj.com] Sent: Wednesday, March 23, 2011 16:14 To: Baehr Capt James S Cc: Workman Maj Adam J Subject: Re: Article 32 witness and discover request I had Beall and removed him. I'll add him again. Haytham Faraj Sent from my iPhone On Mar 23, 2011, at 6:46 PM, "Baehr Capt James S" <james.baehr@usmc.mil> wrote: > Gentlemen, > > Here are my changes. > > Do we want to include in this request all the testimony against our side that is going to come out? There's a decent amount of damaging information in here. > > Do we want to include the testimony of First Sergeant Beall that he told me over the phone about the custodial interrogation techniques or keep that as a surprise? > > Other than that, fixed some spelling errors and added a few things. > - Maps. There were some parts in the discovery were maps were mentioned that were drawn by some folks about the scene. I couldn't find them included, though. I bet they're all unbelievably inconsistent. I think this helps our case theme of complete confusion. > - SA Periard. We need to know everything about this guy. > > R/s, > Jim > > -----Original Message----- > From: Haytham Faraj [mailto:haytham@puckettfaraj.com] > Sent: Wednesday, March 23, 2011 15:09 > To: Workman Maj Adam J; Baehr Capt James S > Subject: Article 32 witness and discover request > > Gentlemen, > > I am attaching the witness and discovery request. Feel free to add to it as you see fit. Between yesterday and today I ended up editing another 12 or so witnesses who something potentially damaging to our case. The way I plan to handle the possibility of such witness statements coming in is by notifying Maj Goode that we object to any statement coming in unless the witness is unavailable. And I also intend to ask for the names and contact numbers of all witnesses that the government intends to call as a witness. I request that Capt Baehr review this first. Please turn on the track charges function. Maj Workman get it second. Adam forward it to me again when you're done so I can take a final chop. > > > > s/f > > > > 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. > > > > <Article 32 disc and witness request jb.doc>
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