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RE: Stip excludable delay and order



Thanks for the clarification, I wasn’t sure who was the intended interviewer and who was the intended interviewee.  I’m sorry, but no government agents will be made available for interviews.

 

Michael C. Martin

Assistant United States Attorney

Eastern District of Michigan

211 West Fort Street, Room 2268

Detroit, MI  48226

(313) 226-9670

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Wednesday, September 22, 2010 11:17 AM
To: Martin, Michael C. (USAMIE)
Subject: RE: Stip excludable delay and order

 

Good morning

I wanted to interview the agents who worked this case.  Agent Rankin said he would not interview with me unless you were also present.

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

_______________________

WASHINGTON DC METRO

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

 

DETROIT METRO

6200 Schaefer Road

Suite 202

Dearborn, MI 48126

313-457-1390 Phone

202-280-1039 Fax

 

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.

 

From: Martin, Michael C. (USAMIE) [mailto:Michael.C.Martin@usdoj.gov]
Sent: Wednesday, September 22, 2010 11:07 AM
To: Haytham Faraj
Subject: RE: Stip excludable delay and order

 

Thanks for the information regarding the plea.  As for the interviews, I’m a little confused.  Do you have someone that you would like Agent Rankin to interview for purposes of providing the government with information?

 

Michael C. Martin

Assistant United States Attorney

Eastern District of Michigan

211 West Fort Street, Room 2268

Detroit, MI  48226

(313) 226-9670

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, September 21, 2010 6:32 PM
To: Martin, Michael C. (USAMIE)
Subject: RE: Stip excludable delay and order

 

Mr. Martin,

I did indeed have someone call to set up some interviews.  We didn’t follow up with you because I was out of town.  We will try to set up interviews again soon.  Is that your position with all the FBI agents?  As far as the plea agreement, Mr. Hamama is simply not provident to a plea of guilty on any charge except, perhaps, the false statement.  The problem remains the confinement recommendation.  The short answer is we can’t accept that agreement.

 

Sincerely,

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

_______________________

WASHINGTON DC METRO

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

 

DETROIT METRO

6200 Schaefer Road

Suite 202

Dearborn, MI 48126

313-457-1390 Phone

202-280-1039 Fax

 

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.

 

From: Martin, Michael C. (USAMIE) [mailto:Michael.C.Martin@usdoj.gov]
Sent: Tuesday, September 21, 2010 4:29 PM
To: Haytham Faraj
Subject: RE: Stip excludable delay and order

 

Mr. Faraj, Agent Rankin received a phone call recently from someone claiming to be from your office requesting a meeting, he directed them to me, but I never heard from them.  In any event, can you tell me where Mr. Hamama stands on the plea, as the deadline has passed.

 

Michael C. Martin

Assistant United States Attorney

Eastern District of Michigan

211 West Fort Street, Room 2268

Detroit, MI  48226

(313) 226-9670

 

From: Martin, Michael C. (USAMIE)
Sent: Monday, August 02, 2010 12:03 PM
To: Haytham Faraj
Subject: RE: Stip excludable delay and order

 

Thanks for the info.  I will keep the plea offer open until September 17th.  If he wants to take advantage of the 34 month cap, he has to accept by that date, as I will not give another extension.  

 

Michael C. Martin

Assistant United States Attorney

Eastern District of Michigan

211 West Fort Street, Room 2268

Detroit, MI  48226

(313) 226-9670

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Saturday, July 31, 2010 5:03 PM
To: Martin, Michael C. (USAMIE)
Subject: RE: Stip excludable delay and order

 

I can’t recall if I answered you on your plea agreement question.  I am going to be meeting with Mr. Hamama again in late August.  Given the January 6 trial date, I’d like to request that you keep the plea option open.  We’ll discuss it some more and come back to you with a definite answer.

 

Best,

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

_______________________

WASHINGTON DC METRO

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

 

DETROIT METRO

6200 Schaefer Road

Suite 202

Dearborn, MI 48126

313-457-1390 Phone

202-280-1039 Fax

 

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.

 

From: Martin, Michael C. (USAMIE) [mailto:Michael.C.Martin@usdoj.gov]
Sent: Tuesday, July 20, 2010 12:06 PM
To: Haytham Faraj
Subject: RE: Stip excludable delay and order

 

This looks good.  In the citation to 18 USC 3161, would you mind also including a citation to subsection (h)(7)(A)?

 

Also, the expiration date for the plea agreement has passed.  Am I correct to assume it has been rejected?

 

Michael C. Martin

Assistant United States Attorney

Eastern District of Michigan

211 West Fort Street, Room 2268

Detroit, MI  48226

(313) 226-9670

 

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Monday, July 19, 2010 11:45 AM
To: Martin, Michael C. (USAMIE)
Subject: Stip excludable delay and order

 

Mr. Martin,

Please review the attached stipulation to see if there’s any additional language you wish to have included before I have Mr. Hamama sign it.

 

Sincerely,

 

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

_______________________

WASHINGTON DC METRO

1800 Diagonal Road

Suite 210

Alexandria, VA 22314

703-706-0442 Phone

 

DETROIT METRO

6200 Schaefer Road

Suite 202

Dearborn, MI 48126

313-457-1390 Phone

202-280-1039 Fax

 

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.