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LT Ray: Upon interviewing some of the witnesses last week, I have
conclusion that I need to file two motions. I am writing to coordinate with
you to see if you are amicable to setting a date and what those dates may be.
I recognize that this may cause a delay in the trial. This was unforeseen. If
we can’t agree then I’ll have to go to the judge and take my lumps. I will
probably take some lumps even if we agree but it can’t be helped. Below is my response to your witnesses email. My comments
are in blue. 1. LT Ross - At this time it is the Government's position
that LT Ross is not a relevant or necessary witness. He has no personal
knowledge of the facts in this case. He can only testify that he passed
information given to him by SN Leamer to the RTC investigators. SN Leamer and
the RTC Investigations will be available to testify at trial. His cell number
is 252-628-9976. I will agree to a stipulation
on him 2. FC3 Salter - The government has interviewed FC3
Salter, his cell number is 770-841-7902. A stipulation of fact may be a possibility
for this witness. I definitely want him
produced 3. SA La Bruyere - Will be provided. 4. SA Peterson - The government has interviewed SA
Peterson. She has no personal knowledge of charged misconduct and therefore it
is the government's position, at this time, that she is not a necessary or
relevant witness. SN Leamer will be there to testify. Her cell phone number
is 623-910-2585. No objection so long as you
agree to telephonic testimony. 5. Chief Barraza - Will be provided. 6. MA1 Matias - Will be provided. 7. SA Brown - Will be provided. 8. SR Gonzalez - Have not been able to make contact. I
believe the ship is underway. Do you have any other contact information for
the ship? I have no other contact
information. 9. SA Jansky - SA Jansky can testify that when he was
in the office nothing inappropriate happened. However, he will also testify
that there were many times he was not in the office when SA Dorion was because
his job required him to be in the office significantly less than the other
yeoman. He was the Master at Arms. The government would be willing to enter
into a stipulation of fact with regards to this witness. His cell number is
860-514-1440. We will agree to telephonic or
a stip 10. SA Martinez - Have attempted to reach her numerous
times, but due to her deployed work schedule and time change in Iraq, there has
been difficulty. At this point no contact has been made. If, after
interviewing this witness, the Government finds her to be necessary and
relevant, the Government would ask that she be able to testify telephonically.
Does defense have any objection? No objection 11. SA Hernandez - Have attempted to contact her, however
she has not returned any phone calls. Her cell number is 626-264-2826. 12. Senior Chief Crisp - Will be provided. 13. AECS Campbell - Have not been able to make contact.
I have sent an email, however I have not heard back. I cannot get his phone
numbers to work. Is there a DSN or alternative phone number? I will contact him and get
back to you. He’s an essential defense witness on the merits and possibly in
sentencing 14. AVCM Spaddy - Have left a message and sent an email,
but AVCM has not contacted me. I have spoken to her. She is
also an essential defense witness 15. LT Lucas - Sent an email, however I have not heard
back. I’ve connected with him and
he will get back to you. I will be on the West Coast 11-16 April. I will try to
call you Monday to discuss scheduling. Are you available for a call between
1500 and 1530? Vr, Haytham Faraj, Esq. PUCKETT & FARAJ, PC WASHINGTON DC׀ SAN DIEGO ׀ DEARBORN 888.970.0005 Toll Free 202.280.1039 Fax 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
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