RE: Witness List and Jury Instructions

[Haytham Faraj <haytham@puckettfaraj.com>]

Thanks Carolynn.  I am at a conference this week. I will review this as soon
as I can and get back to you.

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
_______________________
WASHINGTON DC METRO
1800 Diagonal Road
Suite 210
Alexandria, VA 22314
703-706-0442 Phone

DETROIT METRO
6200 Schaefer Road
Suite 202
Dearborn, MI 48126 
313-457-1390 Phone
202-280-1039 Fax

www.puckettfaraj.com

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-----Original Message-----
From: Carolynn Beck [mailto:carolynn.beck@gmail.com] 
Sent: Friday, July 16, 2010 11:07 AM
To: Haytham Faraj
Subject: Re: Witness List and Jury Instructions

Hi Haytham,

I reorganized the Jury Instruction document a little bit so that it's
clearer which jury instructions go to which count in the indictment, and
(possibly) when they should be used during the trial.. though since I
haven't been through an entire trial before, I may have put them in the
wrong sections. Can you please check those for me and let me know what you
think? I copy-pasted the text from the sections; didn't realize until after
getting your email that this was included in your sample document, sorry
about that. I  also included some notes from the various sections,
specifically for the parts where there are "opinion" or "expert" witnesses,
etc., so that you can take a glance and see whether you want to include
those or not.

Regarding the charges, I used the indictment from 2008 that I received from
you via email a while back - that's the one you're referring to, right? The
counts I was referring to before that weren't in the 6th cir. instructions
were18 U.S.C. § § 371 and 951(a). I put that in the table and in the jury
instructions, but since they weren't listed in the 6th cir. jury
instructions, I didn't have instructions to include.

Also, just so you know, if the formatting is off, it may be because I'm
using a Mac and converted to a word document. I was alerted a week ago that
my formatting was coming out incorrectly on certain people's PC computers...
so hopefully this shows up correctly on your end.

Thank you,

Carolynn Beck
(202) 316-1367



On Jul 16, 2010, at 8:23 AM, Haytham Faraj wrote:

Good work on both. For the time being I don't want you to search for
additional instructions but I would like you to copy and the text into the
jury instruction list.  You said that there were some charges that the jury
instructions did not include which ones are you referring to.  Also, did you
include the charge from the superseding indictment?

Thanks

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
_______________________
WASHINGTON DC METRO
1800 Diagonal Road
Suite 210
Alexndria, VA 22314
703-706-0442 Phone

DETROIT METRO
6200 Schaefer Road
Suite 202
Dearborn, MI 48126
313-457-1390 Phone
202-280-1039 Fax

www.puckettfaraj.com

The information contained in this electronic message is confidential, and is
intended for the use of the individual or entity named above. If you are not
the intended recipient of this message, you are hereby notified that any
use, distribution, copying of disclosure of this communication is strictly
prohibited. If you received this communication in error, please notify
Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender.
You are required to purge this E-mail immediately without reading or making
any copy or distribution.


-----Original Message-----
From: Carolynn Beck [mailto:carolynn.beck@gmail.com]
Sent: Wednesday, July 14, 2010 3:23 PM
To: Haytham Faraj
Subject: Witness List and Jury Instructions

Haytham,

I did as you asked and only inserted the sections that I thought might be
relevant. I wanted to know if you would like me to research outside of the
link that you sent me to try to find jury instructions that are more
favorable to us (? if that is even something that is feasible?) and whether
I should do an outside search to find jury instructions regarding the USC
charges that aren't already in the links for the 6th circuit (in the
indictment the govnt refers to a couple other sections outside of 18 usc
1001, and I wasn't sure if those entailed separate jury instructions).

Regarding the witness list, I went through all our old emails, the
interviews I made, and the interviews that you did, and I filled in as much
information as I could find. For the FBI agents, I wasn't sure whether you
wanted me to just list "FBI Agents" generally, or if you had certain names
in mind. So I skimmed through the discovery disk and put the names that I
thought might potentially be important. I think the last name I listed is
probably going to be the most important hostile witness. What do you think?

Please let me know what I can do next. I wanted to send these over to you
before spending any hours doing outside research on the jury instructions
since you had given me the link and asked me to just copy over the sections
like the sample jury instruction list you had sent me. Is this what you had
had in mind?

Thank you,

Carolynn Beck
(202) 316-1367