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Re: BOP designation challenge



Haytham-

Thank you for your kind words about the seminar.

I do not believe that you are going to be able to upset the cart at this
point unless the client had extreme medical issues.  You can contact the
designator for our district- Lori Colley at (972) 352-4494

m


Miriam L. Siefer
Chief Federal Defender
Legal Aid & Defender Assn
  Federal Defender Office
613 Abbott, 5th Floor
Detroit, MI 48226
313-967-5868  -  Direct Line



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  |Haytham Faraj <haytham@puckettfaraj.com>                                                                                                          |
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  |<miriam_siefer@fd.org>, <jill_price@fd.org>                                                                                                       |
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  |09/15/2011 03:44 PM                                                                                                                               |
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  |BOP designation challenge                                                                                                                         |
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Dear Miriam and Jill,
I want to thank you for the excellent presentation that was put on Tuesday.
I appreciate you and the rest of the staff taking time to share your
knowledge and gifts with us. I would like to ask you a question about a BOP
designation.

I have a client that was recently sentenced by Judge Edmunds.  He was
convicted, at trial, of three counts of false statements.  I beat spying,
conspiracy and financial transactions with a state sponsor of terrorism
charges.  The government sought an increase of 26 points because they
sought to draw a nexus between the false statements conviction and the
untruthful statements about some financial transactions with the government
of Iraq. Judge Edmunds sided with me and granted my motion not to add the
26 points.  For sentencing, I was aiming for probation.  The Government
sought 78 months, the upper limit of the range.  Judge Edmunds gave him 18
months.  My client has no criminal record, is 61 years old and had some
fantastic material for sentencing.  He was credited with saving the lives
of American soldiers by two military commanders in Iraq.  The reason I
share these facts with you is because I believe he should be at an FPC.  He
was assigned to the low security institution in Fort Worth, Texas.  He
lives in San Diego.  I feel that BOP must have erred in their designation
of the security level and that being in Texas will cause a substantial
hardship to his family.
DO you have any recommendations on how I can affect his assignment to a
facility closer to San Diego and if there is any way to get BOP to send him
to an FPC?  I appreciate any advice you may have.

Best,

Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
_______________________
WASHINGTON DC METRO
The Law Firm of Puckett & Faraj, PC
1800 Diagonal Road
Suite 210
Alexandria, VA 22314
703-706-0442 Phone
202-280-1039 Fax

DETROIT METRO
The Law Firm of Puckett & Faraj, PC
835 Mason Street
Suite 150-A
Dearborn, MI 48124
313-457-1390 Phone
202-280-1039 Fax


www.puckettfaraj.com

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