RE: Rowe request for additional discovery

Attached.

From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Wednesday, December 07, 2011 8:11 AM
To: 'Mariam Chamesseddine'
Cc: 'Shinn Capt Scott R'
Subject: Rowe request for additional discovery

Mariam,

Please prepare a discovery request for me for Rowe. Use the letterhead. Ask for the following:

1. A list of all cases in which Dr. Thomas Grieger has testified as an expert in counter-intuitive behavior in sex assault victims, include jurisdictions, and the name and contact information, if available, of the counsel that retained him

2. All studies, papers, research, books, articles, seminar materials or any other writing relied upon by Dr. Grieger to assist him in understanding and evaluating counter-intuitive behavior.

3. Identify all codes as organized within the DSM IV of any disorders that Dr. Grieger intends to rely upon to explain counter-intuitive behavior in Ms. Klay. If he is not relying on the DSM IV. Explain specifically what Dr. Grieger is relying on to reach Ihis conclusions and provide a copy of that material to the defense.

4. Identify the specific behaviors or lack of actions by Ms. Klay that Dr. Grieger concludes are counter-intuitive.

5. Provide a list of matters provided by the Government to Dr. Grieger to assist him in preparing for this trial.

6. Please provide any notes, recordings, checklists, documents, summaries, reports or any other work product prepared by or relied upon by Dr. Grieger in assessing or evaluating Ms. Klay.

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

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