RE: DEFENSE RESPONSE TO GOVT DISCOVERY REQUEST - U.S. v. ADC NATIVIDAD

["Haytham Faraj" <haytham@puckettfaraj.com>]

LT Ray,
Until a more formal response to your request can be prepared, that defense
answers your request for reciprocal discovery as follows:

1.a-c. Will be provided IAW the CMO.
1.d-i.  Not applicable or none known to the defense.

We will notify you of any changes in our response.

Vr,
Haytham Faraj


-----Original Message-----
From: Ray, Katherine S LT RLSO MW, GREAT LAKES
[mailto:katherine.ray@navy.mil] 
Sent: Monday, March 22, 2010 10:32 AM
To: Haytham Faraj
Cc: Griffo, Joseph T LT NLSO MILL; griffo.joseph@gmail.com; Pennix,
Elisabeth H LT RLSO MW
Subject: RE: DEFENSE RESPONSE TO GOVT DISCOVERY REQUEST - U.S. v. ADC
NATIVIDAD

Mr. Faraj,

Can I anticipate a response to the government discovery request by COB
today?  At this point defense is a week late in responding, per the agreed
upon CMO date.  The government strongly wants this case to remain on track
and go to trial the week of 26 April.  

Have a good day. 

V/r,
LT Ray 

-----Original Message-----
From: Haytham Faraj [mailto:haytham@puckettfaraj.com] 
Sent: Thursday, March 18, 2010 5:34
To: Ray, Katherine S LT RLSO MW, GREAT LAKES
Cc: Griffo, Joseph T LT NLSO MILL; <griffo.joseph@gmail.com>; Pennix,
Elisabeth H LT RLSO MW
Subject: Re: DEFENSE RESPONSE TO GOVT DISCOVERY REQUEST - U.S. v. ADC
NATIVIDAD

LT Ray,
I will get you a formal response before COB tomorrow. Apologies for the
missed date.

Vr,

Haytham Faraj
760-521-7934
Sent from my iPhone

On Mar 17, 2010, at 3:36 PM, "Ray, Katherine S LT RLSO MW, GREAT LAKES"
<katherine.ray@navy.mil> wrote:

> Mr. Faraj, LT Griffo,
>
> As a friendly reminder, per the case management order for U.S. v.  
> Natividad, the response to discovery requests was due yesterday, 16 
> March 2010 by close of business.  I have not received anything from 
> defense at this point.  Should I expect the response by the end of 
> today or will defense be asking for an extension from the judiciary?
>
> V/r,
> LT Ray
>
> -----Original Message-----
> From: Ray, Katherine S LT RLSO MW, GREAT LAKES
> Sent: Tuesday, March 16, 2010 15:05
> To: 'Haytham Faraj'; Griffo, Joseph T LT NLSO MILL
> Cc: Pennix, Elisabeth H LT RLSO MW
> Subject: GOVT RESPONSE TO DEFENSE DISCOVERY REQUEST - U.S. v. ADC 
> NATIVIDAD
>
> Mr. Faraj, LT Griffo,
>
> Please see the attached government response to the defense discovery 
> request.  The corresponding documents are being shipped to Mr. Faraj 
> at 2181 Jamieson Ave. Suite 1505, Alexandria, VA, 22314.
>
> Please let me know if you have any questions or concerns.
>
> V/r,
> LT Ray
>
> ---------------------------------
> Katherine S. Ray
> LT, JAGC, USN
> Region Legal Service Office, Midwest
> Comm: 847.688.3805
> Fax: 847.688.2481
> DSN: 792.2480
>
>
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