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Re: Lopez witness interviews
I won't get there until about 0930. I have my assistant working on breaking down the testimonial evidence by category. That should be ready by Friday. We'll work on this tomorrow. We will probably have to ask for a continuance. I can't get my mind around these charges. They're just so ambivalent. I'll see you in the morning.
Haytham Faraj
Sent from my iPhone
On May 10, 2011, at 8:01 PM, "White Capt Bret A" <bret.a.white@usmc.mil> wrote:
> Haytham,
>
> I'm putting the motion to compel witness production together right now. I know I needed to do the initial request differently and that's why we're in a bit of a bind on this now. So, hopefully we can recover in this area.
>
> I listed the 17 2ndLts at TBS in my anticipated witness list, but didn't request their production. I only requested production of out of area witnesses. From dealing with Maj Mitchell in the past, do you think we're going to have a problem getting him to voluntarily let those 17 2ndLts go or do I need to include them in my motion to compel production?
>
> As to the rest of the platoon, they are the only ones who were denied by the government who we need or may need. The question is: do you want me to ask for ALL of them or just some of them? The only ones who were denied in my out of area request who were also named in the charge sheet or bill of particulars are Thompson, Walden, Wilson, Brown, & Partridge. So, I'm prepping the motion to address them and we can add the rest in the morning if you like.
>
> I'll be here a little while longer and probably a little early in the morning. What time are you getting in?
>
> V/r,
>
>
> Bret A. White
> Captain, U.S. Marine Corps
> Defense Counsel
>
> Office of the Staff Judge Advocate
> Marine Corps Base
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> -----Original Message-----
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Tuesday, May 10, 2011 8:13
> To: White Capt Bret A
> Subject: Lopez witness interviews
>
> Good morning Bret,
>
> Please submit a request to have GySgt Kelton produced as a witness. We need that request sent out immediately so we can work through the issue of testimonial immunity. GySgt Kelton is a necessary, relevant and material witness. She is an exculpatory witness to several of the charges on the charges sheet. I have been informed by her counsel that she has testimony that directly contradicts the charged offenses. He would not go into any great detail but shared facts about one charge, the taking of photos of candidates. He told me that Kelton specifically rebuts that. I believe that there will be a lot more.
>
> Also please prepare and submit a simple witness production motion for all witnesses that you believe are relevant but that the Government denied. Do not go into great detail on the law. The judge knows the law. Provide the facts necessary to show why the witnesses are relevant and necessary to persuade the judge. Let me know if youâre available tomorrow morning.
>
>
>
> Haytham Faraj, Esq.
>
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