Haytham,I did as you asked and only inserted the sections that I thought might be relevant. I wanted to know if you would like me to research outside of the link that you sent me to try to find jury instructions that are more favorable to us (? if that is even something that is feasible?) and whether I should do an outside search to find jury instructions regarding the USC charges that aren't already in the links for the 6th circuit (in the indictment the govnt refers to a couple other sections outside of 18 usc 1001, and I wasn't sure if those entailed separate jury instructions).
Regarding the witness list, I went through all our old emails, the interviews I made, and the interviews that you did, and I filled in as much information as I could find. For the FBI agents, I wasn't sure whether you wanted me to just list "FBI Agents" generally, or if you had certain names in mind. So I skimmed through the discovery disk and put the names that I thought might potentially be important. I think the last name I listed is probably going to be the most important hostile witness. What do you think?
Please let me know what I can do next. I wanted to send these over to you before spending any hours doing outside research on the jury instructions since you had given me the link and asked me to just copy over the sections like the sample jury instruction list you had sent me. Is this what you had had in mind?
Thank you, Carolynn Beck (202) 316-1367
Attachment:
Hamama_witness_list.doc
Description: MS-Word document
Attachment:
Hamama_Jury_Instructions.doc
Description: MS-Word document