John, Attached are some motions that could help you in Vega. Christian P. Hur Captain, USMC Senior Defense Counsel Telephone: (619) 524-8713 Fax: (619) 524-6784 Address: Defense Section, Bldg 12, 1st Floor, MCRD, San Diego, CA 92140 This email may contain Attorney Work Product. Please delete if you received this message in error. -----Original Message----- From: Boyer Capt John F Sent: Friday, October 15, 2010 9:17 To: Hur Capt Christian P Subject: FW: Vega pretrial prep -----Original Message----- From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Sent: Friday, October 15, 2010 9:09 To: Boyer Capt John F Subject: RE: Vega pretrial prep Do you have a standard discovery request? I would ask for Kayla because she's an impeachment witness. We know they're calling Dana. We should include in the discovery request a request for the names and contact information of all government witnesses. The request for the list of counselors should also include the contact information of the counselors and discovery of all counseling records for our client and Orcutt, counselors notes and appointment calenders. -----Original Message----- From: Boyer Capt John F [mailto:john.boyer@usmc.mil] Sent: Friday, October 15, 2010 11:58 AM To: Haytham Faraj Subject: 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. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO The Law Firm of Puckett & Faraj, PC 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone 202-280-1039 Fax DETROIT METRO The Law Firm of Puckett & Faraj, PC P.O. Box 1016 Dearborn Heights, MI 48127 313-457-1390 Phone 202-280-1039 Fax www.puckettfaraj.com <http://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.
Attachment:
Egnash DISCOVERY REQUEST.doc
Description: MS-Word document
Attachment:
Brito Motion to dismiss multiplicity HF edits.doc
Description: MS-Word document
Attachment:
Brito Article 13 motion hur edits.doc
Description: MS-Word document
Attachment:
Brito Motion to exclude statement HF edits.doc
Description: MS-Word document
Attachment:
Brito Motion to dismiss MPO.doc
Description: MS-Word document
Attachment:
smime.p7s
Description: S/MIME cryptographic signature