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RE: U.S. v. Card prep



Any word on our site visit?

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Wednesday, February 16, 2011 14:48
To: Workman Maj Adam J; Baehr Capt James S
Subject: RE: U.S. v. Card prep

Just got some interesting info from the SJA.  They have been directed to not
withhold funds or support in producing all necessary witnesses.  The
objective is to allow the defense to fully cross examine everyone so that
that IO can decide whether any of these charges have any validity.

I am now thinking we need to divide up the work, contact all the witnesses
and see which ones are friendly to us or feel like they were pressured by
the NCIS.

I'll try to get you both on a call tomorrow.

-----Original Message-----
From: Workman Maj Adam J [mailto:adam.j.workman1@usmc.mil] 
Sent: Wednesday, February 16, 2011 5:38 PM
To: Haytham Faraj; Baehr Capt James S
Subject: RE: U.S. v. Card prep

Haytham,

I am available to chat whenever you and Baehr are.  I am in Lemoore for an
Art 32 Thursday and Friday but will be spending a lot of time driving and
will be available on my cell.

Adam
760-805-7212

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Wednesday, February 16, 2011 12:49
To: Baehr Capt James S; Workman Maj Adam J
Subject: U.S. v. Card prep

Gentlemen,
Are you done with the discovery.  I'd like to put together a discovery
request and move in to witness interview plan.  Before we do that, I'd like
to have a chat about our defense theory.  From that we will identify the
people or evidence that will support our theory.

-----Original Message-----
From: Baehr Capt James S [mailto:james.baehr@usmc.mil] 
Sent: Monday, February 14, 2011 5:31 PM
To: Workman Maj Adam J; haytham@puckettfaraj.com
Subject: FW: Sent via Google Maps: James Baehr sent you: A Maps link

Gentlemen,

I read through all of the discovery on Saturday, and went into Google Maps
to try and get an understanding of the site Phillips was talking about. The
link below should connect you to the location that NCIS and Phillips settled
on. Hopefully, my pins on the map to indicate where Phillips indicated
things happened will show up as well.

R/s,
Jim


Capt James S. Baehr, USMC
Defense Counsel
Legal Team Echo
(w): 760-725-4016
(c): 404-375-1305 




-----Original Message-----
From: James Baehr [mailto:jimmybaehr@gmail.com] 
Sent: Saturday, February 12, 2011 11:40
To: Baehr Capt James S
Subject: Sent via Google Maps: James Baehr sent you: A Maps link


This email was sent to you by a user on Google Maps:

Mapping of site.

________________________________


Hi, I'd like to share a Google Maps link with you. Link:
<http://maps.google.com/maps/ms?ie=UTF8&hl=en&msa=0&ll=33.434414,43.31406&sp
n=0.005265,0.008615&t=h&z=17&msid=206323486269633889414.00049c1839d68a042c7a
8>


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