Re: Update (UNCLASSIFIED)

[Haytham Faraj <haytham@puckettfaraj.com>]

That's fine. 

Haytham Faraj
Sent from my iPad

On Jul 22, 2011, at 12:49 PM, "Douglas, Laquisha S CPT MIL USA FORSCOM" <laquisha.douglas@us.army.mil> wrote:

> Classification: UNCLASSIFIED
> Caveats: FOUO
> 
> Okay. I will hold off on submitting the motion today, and find out if
> they will agree to waive the objection. The civilian paralegal is only
> doing Houda's testimony. Is that okay with you?
> 
> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
> Sent: Friday, July 22, 2011 9:28 AM
> To: Douglas, Laquisha S CPT MIL USA FORSCOM
> Subject: Re: Update (UNCLASSIFIED)
> 
> 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>
> Classification: UNCLASSIFIED
> Caveats: FOUO
> 
>