U.S. v. Hamama Tasking

Carolynn:

I have attached the following:

1. Example shell motion in limine to preclude admission of hearsay under co-conspirator theory

2. Gov’t motion to admit documents in the Shaoul case (companion case in the Central District of CA)

3. Gov’t motion to admit documents in the Shemami Case (companion case from the Eastern District of MI)

4. IIS documents (Discovery disk 1)

5. Indictment

Your task is as follows:

Use the document labeled motion in limine to preclude Admission of hearsay (co-conspirator) as your base motion. You should begin by reading the indictment and reviewing the IIS documents labeled discovery disk1. That will give you an idea of the facts of the case. You may call when you have completed reviewing those documents to get clarification. Once you are oriented on the facts, read the two motions from Shemami and Shaoul to understand the government argument. It’s essentially the same. Your objective is to persuade the court to grant us a hearing where the government would have to prove up the conspiracy before they can admit those documents. I would structure the issue in this way: Whether the government should be required to prove the existence of a conspiracy against a defendant before it can preadmit hearsay documents created by the Iraqi intelligence Service, an organization that frequently fabricated evidence against people it considered enemies of the Saddam Hussein Regime, under the co-conspirator exception to the hearsay rule? That’s just one way to style the issue but it gives you an idea.

You may do your research by going to the www.ISBA.org

Logon by using 202781 as the user name and “Faraj1986” as the password. It’s case sensitive. Once you’re on the website click the “Fastcase” button. It’s pretty simple. It also has a tutorial. If necessary, I will cover an hour for the tutorial. Please make sure you indicate that in your time sheet. DO NOT include it as research.

Haytham Faraj, Esq.

PUCKETT & FARAJ, PC

WASHINGTON DC׀ SAN DIEGO ׀ DEARBORN

www.puckettfaraj.com

888.970.0005 Toll Free

202.280.1039 Fax

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