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RE: Vega pretrial prep



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

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-----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

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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