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Re: Hamama request for a designation



Judge Edmunds will recommend designation to a facility in California as close to San Diego as possible.  BOP determines the security level.




Carol A. Hemeyer
Case Manager
Honorable Nancy G. Edmunds
United States District Court
(313) 234-5157







From:        Haytham Faraj <haytham@puckettfaraj.com>
To:        <Carol_Hemeyer@mied.uscourts.gov>
Cc:        "'Martin, Michael C. \(USAMIE\)'" <Michael.C.Martin@usdoj.gov>
Date:        08/23/2011 09:03 AM
Subject:        Hamama request for a designation




Dear Ms. Hemeyer,
This is a request for a designation of a region and facility for Mr. Hamama.
Mr. Hamama respectfully requests that the court designate a minimum security -Federal Prison Camp- in the San Diego or Los Angeles areas and a if such a facility is not available that Mr. Hamama be assigned to a Residential Reentry Center (RRC).  See 18 U.S.C 3621(b)(4).  Mr. Hamama declined to request that the court make a designation  during sentencing so that he may research the available facilities and discuss the options and criteria for assignment to a particular facility with his counsel so that he may determine those that are best suited to achieve the objective of sentencing without undue hardship on he and his family.

Mr. Hamama requests a facility that is reasonably close to his home in San Diego, CA, where his wife will reside alone.  Mr. Hamama also requests that the facility provide training and vocational programs that will provide Mr. Hamama with training that will enable him to obtain employment upon release. Mr. Hamama is 61 years old and a convicted felon.  It is unlikely that he will be able to successfully compete for employment upon release unless he can demonstrate a unique skill or training in a vocation.  Mr. Hamama’s employer will not hold his current job for him until he is released.

Employment post release will be critical to allow Mr. Hamama to reintegrate into society. Employment will also contribute to his ability to find housing and to provide for his family. It is expected that Mr. and Mrs. Hamama will lose their home to the bank in the next 60-90 days. Mrs. Hamama will have to live with relatives.  While she is currently employed as a teacher's assistant her salary is meager and insufficient to enable her to pay for a home without Mr. Hamama's income.  Accordingly, any skill or training that Mr. Hamama can learn that will assist him in obtaining employment will enable Mr. and Mrs. Hamama to rebuild their lives without relying on government of private assistance.


Being at a facility near San Diego is critically important to avoid a greater hardship than necessary. Mrs. Hamama is very dependent on Mr. Hamama. His long absences while serving in Iraq with the U.S. Armed Forces have caused her to become intensely protective and very attached to him. Custody in a facility that is not reasonably close to San Diego will enhance the punishment and hardship on Mr. and Mrs. Hamama, more than necessary to achieve the purposes of punishment.

Mr. Hamama respectfully requests that the court recommend a Federal Prison Camp, in the San Diego or Los Angeles areas.  If and FPC is not available, Mr. Hamama respectfully requests an RRC.

 
Very respectfully submitted,
 
Haytham Faraj, Esq.
PUCKETT & FARAJ, PC
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