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RE: Addl Discovery ICO Sgt Barillas



Roger that. Concur with admitting fingerprint report w/o expert. Let's get Huff approved and get him all he'll need. He worked the murder case with me and helped win it. He also said we may be better off with a toxicology expert but he'll let us know after he reviews everything. I'll keep you posted. Shoot me your work phone again, please.
Neal
Neal A. Puckett, Esq.
LtCol, USMC (Ret)
The Law Firm of Puckett & Faraj, PC
Washington DC - San Diego CA
www.puckettfaraj.com
888.970.0005


Quoting Dempsey Capt Suzanne M <suzanne.dempsey@usmc.mil>:

Neal,

That's great.  Congrats on your victory.

My next three weeks are fairly open, so almost any time should work to meet.
Next week the only conflict I have right now is an adboard on Tuesday.
Otherwise, my week is open.

I talked to Maj Plummer last week.  He would like to introduce the one page
report about the fingerprints that were found on the window w/o actually
bringing the fingerprint expert to testify.  If we do not object to that, he
is willing to provide us with Col Huff.  If we are going to concede that
point anyway, I do not see a problem with not having the expert testify.  I
got all the relevant docs scanned, so I will get those sent off to Col Huff
so he can begin reviewing them.

Our motions deadline was today.  The only motion I filed was the motion to
dismiss regarding the constitutional issue.  This motion was granted
recently in a case in the southeast.  It has also been granted in Pensacola.
I attached the most recent judge's findings and the Govt's response.  It has
not been heard yet in our jurisdiction.  There is another case that will be
arguing the same motion here about 2 weeks before our motions hearing.  It
will be interesting to see what ruling we get on the west coast.

I am working through the final witness issues with Maj Plummer.  He is
willing to provide most of the witnesses, just some of the contact info was
out of date.  We can talk about the others to see if you think they are
worth the fight.  I do not think they really add much.

Suzy





-----Original Message-----
From: neal@puckettfaraj.com [mailto:neal@puckettfaraj.com]
Sent: Wednesday, October 01, 2008 18:01
To: Dempsey Capt Suzanne M
Cc: Haytham Faraj
Subject: Re: Addl Discovery ICO Sgt Barillas

Thanks, Suzy.  Departing Okinawa in a few hours after winning the murder
case this week.  Will be in So. CA for the next 3 weeks.  Will touch base
with you soon.  Mr. Faraj will be in town, as well.  We'll visit you and
client, if he's off the range yet.  :) Neal A. Puckett, Esq.
LtCol, USMC (Ret)
The Law Firm of Puckett & Faraj, PC
Washington DC - San Diego CA
www.puckettfaraj.com
888.970.0005


Quoting Dempsey Capt Suzanne M <suzanne.dempsey@usmc.mil>:

Sir,

Please find attached a request for additional discovery ICO Sgt Barillas.

V/r,

Capt Dempsey