RE: US v. Saleh Notice of appearance and EDR (UNCLASSIFIED)

[Haytham Faraj <haytham@puckettfaraj.com>]

Laquisha,
Would you file a motion to continue until August 22.  The reasons are:
1.  We need time to identify a DNA expert and require time to have that
expert review the evidence.  Based on my experience USACIL will not give us
one of their experts because there is a conflict.  That means we will have
to find our own expert.  DNA experts are typically overbooked and difficult
to get on short notice.  I know someone in Sothern California that I will
contact to see if she is available.
2.  We need time to identify a forensic behavioral psychologist to assist us
with the evidence. 
3.  My schedule is booked and I am unavailable until August 22.  I am
scheduled for trial as follows:  June 27-July 22 U.S. v. Wuterich; August
3-12 U.S. v. Lopez; I am also trying the case of U.S. v. Burke which is
double booked with Lopez. 


Vr,
Haytham

-----Original Message-----
From: Wright, Matthew E CPT MIL US USA FORSCOM
[mailto:matt.wright@us.army.mil] 
Sent: Tuesday, May 31, 2011 5:31 PM
To: Haytham Faraj
Cc: Douglas, Laquisha S CPT MIL USA FORSCOM; Wardlow, Russell D CPT MIL US
USA FORSCOM
Subject: RE: US v. Saleh Notice of appearance and EDR (UNCLASSIFIED)

Classification: UNCLASSIFIED
Caveats: FOUO

Mr. Faraj,

The Pre-Trial Order was issued this morning.  I appreciate the difficulties
involved in trying to get everyone on the same page.  Since the PTO has been
issued, I believe you will need to submit a motion asking for a continuance.


V/R,
Matt Wright
CPT, JA
Trial Counsel

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
Sent: Tuesday, May 31, 2011 11:07 AM
To: Wright, Matthew E CPT MIL US USA FORSCOM
Cc: Douglas, Laquisha S CPT MIL USA FORSCOM
Subject: US v. Saleh Notice of appearance and EDR

CPT Wright,
I am the civilian counsel for SPC Saleh.  I apologize that we could not
connect before the docketing request was submitted.  It appears that there
was a disconnect between me and CPT Douglas.  I have attached a notice of
appearance and an amended docketing request.  

It appears that you will be using a psychologist and a DNA expert.  Would
you please forward me the information on your experts and their CVs so we
may also begin to look for Defense experts.  

Vr,

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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Classification: UNCLASSIFIED
Caveats: FOUO