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 _______________________ 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 835 Mason Street Suite 150-A Dearborn, MI 48124 313-457-1390 Phone 202-280-1039 Fax 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 703-706-0442 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. |