Defense notice of intent to file additional motions in U.S. v. Wylde and other pretrial issues

[Haytham Faraj <haytham@puckettfaraj.com>]

Your honor,
I would like to provide notice that we will have three motions in limine to
be handled before we start the Wylde trial.  They are:

1. Motion in limine to preclude any mention of PFC Wiley's medical/mental
health issues by any witness, including Wiley, unless the government first
establishes that the proffered condition was caused by the ingestion of a
substance provided by PFC Wylde pursuant to  M.R.E. 401 and 403.  See also
M.R.E. 404b.

2.  Motion in limine to preclude any admission or confession of the accused
unless it can first be independently corroborated pursuant to M.R.E. 304(g).

3.  Motion in Limine to preclude the testimony of any expert unless a report
of such expert's putative testimony is provided to the defense beforehand.


I will provide short briefs before COB Friday.  I believe these are all
evidentiary matters that the Court would have to take up during the course
of the trial before the evidence is presented in open court.  I intend to
move that we address them before we begin on Monday.  

Finally, there is a matter that I believe could cause potential delay.  Our
Government appointed expert informed me today that he has been advised by
his command that they can only support the Government's request to provide
one expert rather than two due to the potential conflict that will arise
from having two experts from the same department in the same case. Trial
counsel and I discussed this issue last week and I waived the conflict.  It
appears that the command has raised the conflict issue.  That will mean that
the Government will probably need time to find another expert.  I'll keep
the court updated on the latest developments.

Vr,
Haytham Faraj