I have no idea. I didn't ask for anything and was still waiting for Sanzi to give us his witness request deadline like he said he was going to. Looks like they are charging us for the delay as well. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Monday, March 21, 2011 12:00 To: Workman Maj Adam J; Baehr Capt James S Cc: 'Ted card' Subject: RE: Witness interviews Who asked to delay until April 18? I submitted no such request. Sanzi approached me and said he needs to ask for delay. -----Original Message----- From: Workman Maj Adam J [mailto:adam.j.workman1@usmc.mil] Sent: Monday, March 21, 2011 2:44 PM To: Haytham Faraj; Baehr Capt James S Cc: Ted card Subject: RE: Witness interviews I will be available at 0730. I will actually be heading up to 29P for a 39(a) that starts at 1100. I got these attachments late last week during a contested court-martial and made the mistake of assuming you were in the 'to' line. Our delay has been approved and we now have LtCol Rubin. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Monday, March 21, 2011 11:40 To: Workman Maj Adam J; Baehr Capt James S Cc: 'Ted card' Subject: RE: Witness interviews Let's have a conference call on this tomorrow. LtCol Sanzi told me he is trying to postpone by 2 weeks but never got back to me. What I want to discuss is the benefit of not calling people if they have damaging statements against Maj Card. Is there any benefit? The Government can't bring the statement in unless they invite people to show up and they decline. If we ask for them and they don't show up then the statements come in. But if we don't ask for witnesses to be produced and the government does not have a paper trial that they invited them, then the statements don't come in. Think about these matters and let's talk tomorrow. I am available between 0730 and 1000 your time. Please let me know if we can do it at 0730. -----Original Message----- From: Workman Maj Adam J [mailto:adam.j.workman1@usmc.mil] Sent: Monday, March 21, 2011 2:35 PM To: Baehr Capt James S; Haytham Faraj Cc: Ted card Subject: RE: Witness interviews Gentlemen, I finally got a hold of Andrew Tipton today. Attached are my notes I took as we discussed. He has very little recollection, and therefore not a very fruitful conversation. Although that is obviously a good thing for us. I did not confront him with the signed statement he made. I would like to do that in person so I can evaluate the non-verbals. Seemed like a nice guy and very sincere. I have also attached the notes I took for the other witnesses I interviewed for Ted's benefit since I don't think he has seen them yet. V/r Adam -----Original Message----- From: Baehr Capt James S Sent: Friday, February 18, 2011 14:02 To: Haytham Faraj; Workman Maj Adam J Cc: Ted card Subject: RE: Witness interviews Gentlemen, I attempted to call the 1stSgt and Mr. Jimenez. Mr. Jimenez told me to call him today after work at 6pm. 1stSgt Beall said he could talk more fully after the weekend, but expressed a lot of hostility about the NCIS investigation. "I wouldn't really give a shit to see any NCIS investigation." "They weren't going to let me go until I said what they wanted." - 7 hours of interrogation. - At a police station in Shanohan, IL. - Didn't know Periard before that. - Periard guided him towards answers that he wanted. 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.
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