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Mr. Hamama, by and through undersigned counsel, respecfully requests that the judge designate Terminal Island CA as the facility in which Mr. Hamama should serve his sentence. Mr. Hamama declined to request that the court make a designation during sentencing so that he may research the available facilities with his counsel and determine which are best suited for him.
Mr. Hamama requests Terminal Island because it is reasonably close to his home where his wife resides alone. Terminal Island is also appropriate because it has a number of vocational programs that will provide Mr. Hamama with training that will enable him to obtain employment upon release. Mr. Hamama is 61 years. It is unlikely and 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.
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. Wile 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, and skill or training that Mr. Hamama can learn that will assist him in obtaining employment will enable Mr. and Mrs. Hamama in rebuilding their lives.
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 ultra protective and attached to him, not unlike the spouses of deployed service members. Custody in a facility that is not reasonably close will serve to punish Mr. Hamama more than is necessary to achieve the purposes of punishment.
The Terminal Island facility is uniquely suited to achieve the purpose of punishment while providing Mr. Hamama with the training necessary and availing him of programs that will enable him to rehabilitate himself and rebuild his life, without having to ask the state for aid upon his release.
Mr. Hamama respectfully requests that the court recommend that if Terminal Island cannot accomodate Mr. Hamama, that he be assigned to a minimum security facility close to San Diego, California. And that he be assigned to Terminal Island upon space becoming available.
Haytham Faraj
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