RE: Witness List and Jury Instructions

[Haytham Faraj <haytham@puckettfaraj.com>]

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
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-----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