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RE: Saleh



Thank you Laquisha.  I made my way through the transcript that you sent me.  I have the following thoughts:

 

1.        We need to file a motion in limine to prohibit hearsay statements from Houda as to what Zahra told her or what her impressions were regarding their relationship unless the government can establish a foundation.

2.       I will be requesting from the judge that we submit additional members questions since he does not want to give us voir dire.

3.       We need to call the CID agent(s) that took Chaji’s statements as witnesses.  If they’re on the witness list then nothing needs to be done.

Vr,

Haytham

 

From: Laquisha Douglas [mailto:shalon122@gmail.com]
Sent: Sunday, August 14, 2011 4:06 PM
To: Haytham Faraj
Subject: Re: Saleh

 

Haytham,

 

Here are a couple of updates based on our conversation on Thursday. The transcript is slowly but surely getting done. Attached is about the first hour and 20 minutes of it. I've had my only NCO out of the office working on it all of last week and this weekend. She is about 2 hours into Houda's testimony. I will get a status check from her this afternoon, and hopefully send you the completed version tomorrow. I'm sorry this has taken so long, but she is doing all that she can to finish right now. She will be available as a witness if we need her.

 

I forwarded you two e-mails. One has the additional discovery attached; the other has the final witness list. The government has agreed to produce all of our witnesses. Attached are notes from the character witnesses we were able to interview. I need to call Mr. Ross Little because he may have a financial issue that he believes will prevent him from coming.Also Kaswell is set to deploy, so I will check with the government on his status for the court-martial.

 

Let me know if you need anything else. I have two courts-martial this week, but they are local. I will be checking my e-mail as often as possible.

 

V/R,

 

Laquisha



 

On Thu, Aug 11, 2011 at 9:25 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote:

Please see below. 

Haytham Faraj 

Sent from my iPhone


Begin forwarded message:

From: Haytham Faraj <haytham@puckettfaraj.com>
Date: August 10, 2011 10:13:13 AM EDT
To: Laquisha S CPT MIL USA FORSCOM Douglas <laquisha.douglas@us.army.mil>
Subject: Saleh

Laquisha,
Congratulations on a fantastic outcome in Winfield. You must be feeling good about it. I understand there is some additional evidence on a shared drive. Would you please forward that to me? Also it has come to my attention that a paralegal in your office has communicated at least to one witness, according to our client, that testifying for Saleh would not be a good career move. If that is true it would be a serious matter that could result in IAC and obstruction claims, as well as a violation of the the UCMJ. Please investigate  the matter and let me know what you find out. This requires your immediate attention.
Would you send me a final list of the witnesses that will be available. I still don't have a good grasp on who will be available, including good character witnesses.
Finally, do you have an estimate as to when you believe the transcript will be completed? We still need to ask the government to stipulate to it's admissibility or your paralegal needs to certify it as accurate and be available to testify as a foundation witness.

I'm available to discuss these matters this week. Call me at your convenience.

Haytham Faraj
Sent from my iPad