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RE: Vega pretrial prep



Sir,

I'm in the same spot, but am working on them today.

I have on my to-do list:

Discovery - highlighting
-Joint ethics reg
-Police reports for stolen gun
-All reports filed by Vega b/t Dec 2007-Jan 2009
-NCIC check of Dana Orcutt and Emilio (JR) Guerrero of San Jacinto, CA
-List of counselors working or who worked at MCRD Family Services in 2009 - permanent, part time, temporary
-Record of counseling for Vega and Dana
-Verbatim transcript of Dana's testimony
-Verbatim transcript of MJO clerk's testimony (threat)
-Transcribed statement of Vega (NCIS interview) if the gov is going to offer it
-Kayla Orcutt diary [Logan reported, she could not find it/it does not exist - I will still request]
-If they produce Dana, we want Kayla to come (is this a witness request, or something different?)

Motions:
-Motion in Limine to prohibit bringing up bubblegum incident
-Motion to suppress indecent language based on freedom of speech
-Motion to suppress uncorroborated statements (of Vega to NCIS), based on MRE 304(g) - assuming Nuvia won't come in to testify

I have not heard about any good mil character or alibi witnesses from Vega.

If I've missed something or screwed something up, please let me know.

V/R,

John

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Friday, October 15, 2010 8:41
To: Boyer Capt John F
Subject: Vega pretrial prep

Hi John,

I've lost SA on some of our pretrial prep in Vega.  I think we owe a witness request and a discovery request.  Did you send those out.  I don't recall seeing either and have seen no response by the government.  Did SSgt Vega discuss good character witnesses with us and possibly Albi witnesses?  I'm available to discuss it today.

 

Haytham Faraj, Esq.

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