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U.S. Department of Justice United States Attorney Eastern District of New York |
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One Pierrepont Plaza Brooklyn, New York 11201 147 Pierrepont Street Brooklyn, New York 11201 |
November 3, 2004 |
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| Michael G. Considine, Esq. .Day, Berry & Howard LLP One Canterbury Green Stamford, Connecticut 06901 |
William B. Fleming, Esq Gage, Spencer & Fleming 410 Park Avenue, Suite 900 New York, New York 10022 |
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Herald P. Fahringer, Esq. Lipsitz, Green & Fahringer 780 Third Avenue, 32nd Floor New York, New York 10017 |
David G. Ironman, Esq. 2555 Richmond Avenue, 2nd Fl. Staten Island, New York 10314 |
Re: United States v. Thomas P. McGuire,
et al.
Criminal Docket No. 03 CR 191 (S-6) (SJ)
Dear Counsel:
We write to advise you of the witnesses we expect to
call during roughly the first two weeks of trial.
The first week, we expect to call John Mitchell and Ralph Garguilo. We expect to call records custodians or read any stipulations regarding records between testimony of Mitchell and Garguilo. We have enclosed proposed stipulations relating to the records, as well as the International Union and the transcripts from the tapes.
Thereafter, we expect to call Joseph Coriasco, Patrick Keenan and Jessica
Stuckey. The order will depending on what works best to keep the trial days
full.
As the trial progresses, we will advise you of the order in which we expect
to call the remaining witnesses.
If you would forward your witness list and advise us concerning the stipulations at your earliest convenience we would be appreciative.
Respectfully submitted,
ROSLYNN R. MAUSKOPF
UNITED STATES ATTORNEY
EASTERN DISTRICT OF NEW YORK
By: _____________________________
Bridget Rohde/Joey Lipton
Assistant U.S. Attorneys
cc: Clerk of the Court (SJ)