Ok, I always disclose everything too. I'll coordinate with all of them. Charles C. Gough LT, JAGC, USN Naval Legal Service Office North Central Detachment Great Lakes 2540 Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 (847) 688-4753, extension 108 FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received. -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Friday, November 12, 2010 9:16 To: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES Subject: RE: update on witnesses I am all about disclosing everything to witnesses that way they're not surprised by the inevitable cross examination questions that will be asked. Telephonic is better than statements because the members can also ask questions. -----Original Message----- From: Gough, Charles C LTJG NLSO NC DET, GREAT LAKES [mailto:charles.c.gough@navy.mil] Sent: Friday, November 12, 2010 9:33 AM To: Haytham Faraj Subject: update on witnesses Mr. Faraj, Just an update, I've called the following recruits: Tabitha Bonner, Chandra Tremayne, Danielle Craig, and Nieves Medrano. I left messages with all them. Ms. Craig got back to me and said she'd been called by Miriam already (there were two Craigs that Wofford gave me) but that she'd call me today. Also, I've confirmed that Richard Randall, (a former senior chief) LT Shaun Dennis, and CDR Mark Terrell would all be willing and able to be character witnesses. Should we plan on having them get us letters or testify telephonically? Also, if telephonically, how much information as to the charges and evidence should we give them? Should I give them the charge sheets, or is that too much? Thanks. V/R, LT Gough Charles C. Gough LT, JAGC, USN Naval Legal Service Office North Central Detachment Great Lakes 2540 Paul Jones Street, Bldg 2, Ste 100 Great Lakes, IL 60088 (847) 688-4753, extension 108 FOR OFFICIAL USE ONLY - Privacy Sensitive - Any misuse or unauthorized disclosure can result in both civil and criminal penalties. NOTICE: This e-mail communication is for the sole use of the intended recipient(s) and may contain unclassified confidential and/or attorney-client privileged information. Any unauthorized disclosure, copying or dissemination of this communication is prohibited. If you are not the intended recipient, please notify the sender by telephone or e-mail and delete all copies received.
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