Mr. Martin. I agree to this stipulation. From: Martin, Michael C. (USAMIE) [mailto:Michael.C.Martin@usdoj.gov] Mr. Faraj, I see your point about the AG notification stip. It wasn’t my intention to word it so that it would sound like Mr. Hamama is agreeing that he worked as an agent. I’ve reworded the stipulation in a way that I think addresses your concern and basically makes clear that he is simply agreeing that his name wasn’t in DOJ database. Let me know if this is acceptable to you, or if you would like to alter the language. As you know, the Court has given us a limited amount of time to get this case done and I don’t want to call witnesses if we can work out an accommodation. From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Mr. Martin. I cannot agree to the “stip to AG Notification.” I have a problem with the way it is worded. Specifically, it sounded as if Mr. Hamama is agreeing that he was working as an unregistered foreign agent. As I thought about it, I think this is a matter that is to be determined by the fact finder. You can ask for a jury instruction that instructs the Jury of the existence of the law. I agree to the stipulation regarding the search warrant conditioned on your providing me the specific exhibits the stipulation references. I already have them in Discovery but would like to see the marked exhibits. Sincerely, Haytham Faraj From: Martin, Michael C. (USAMIE) [mailto:Michael.C.Martin@usdoj.gov] Mr. Faraj, attached are two stipulations. Please let me know as soon as possible whether you will agree to these stipulations, as it will save two witnesses travel over the new year holiday. <<Stip to AG Notification.pdf>> <<Stip to Search Warrant Returns.pdf>> Michael C. Martin Assistant United States Attorney Eastern District of Michigan 211 West Fort Street, Room 2268 Detroit, MI 48226 (313) 226-9670 |