Re: Update (UNCLASSIFIED)

[Haytham Faraj <haytham@puckettfaraj.com>]

I'm overseas. I think having the paralegal do it and asking the government to wave objections is reasonable. What I do in civilian practice is call the government and ask them to wave authentication objection. If they don't, I state so in the motion and ask the court to either pay for a court reporter or pre admit over government objection. 

Haytham Faraj
Sent from my iPad

On Jul 21, 2011, at 9:06 PM, "Douglas, Laquisha S CPT MIL USA FORSCOM" <laquisha.douglas@us.army.mil> wrote:

> Classification: UNCLASSIFIED
> Caveats: FOUO
> 
> Mr. Faraj,
> 
> Attached is the motion to compel the verbatim transcript. I plan on
> filing it tomorrow, but I wanted to speak to you about it first. I have
> found one of the secretaries from Legal Assistance who is willing to
> transcribe Houda's testimony for us because she has nothing else better
> to do over there. I need to make sure that is okay with her supervisor
> first, but I wanted to know if that made a difference to you as far as
> the motion to compel goes. 
> 
> My supervisor suggested having the secretary transcribe it and see if
> the Government would be amenable to pre-admitting it as an exhibit. If
> they have an authentication objection, then we could file motion to
> pre-admit it using the Government's denial for our verbatim transcript
> request as a basis. Either way is fine with me, I just wanted to bring
> that to your attention.
> 
> I will also submit the witness production request tomorrow. We cut one
> or two people who did not want to testify. They all have had  initial
> interviews. I suspect that the government is going to refuse to produce
> some of the family members (Saleh's mom, stepdad, sister, brother are
> all on the list) unless they have something very unique to say. 
> 
> I will Cc you on everything tomorrow and give you a call.
> 
> Thanks, 
> 
> 
> CPT Laquisha Douglas
> Defense Counsel
> Fort Irwin Field Office
> U.S. Army Trial Defense Service
> P: 760-380-4199
> F: 760-380-5901
> 
> 
> Classification: UNCLASSIFIED
> Caveats: FOUO
> 
> 
> <Motion to Compel Verbatim Transcript.docx>