Mr. Martin, You brought something up that I had not thought about. I am going to look into it. I’ll let you know if I need to file a motion. Have a good weekend. From: Martin, Michael C. (USAMIE) [mailto:Michael.C.Martin@usdoj.gov] Mr. Faraj, we cannot agree to such an extension because we do not understand why the paperwork cannot be completed with Mr. Hamama reporting as scheduled. If his primary concern is his ability to sign paperwork, he could simply grant his wife power-of-attorney to sign the documents for him. In addition, there is no reason to think that mail service, UPS or Fed Ex would not be able to deliver documents to Mr. Hamama in a timely fashion. Have you attempted to contact the prison in Texas to explain the situation and see if there would be any problems with his mail delivery? We suspect that you would find that the mail delivery would be adequate for his needs. Lastly, we are not at all confident that the paperwork will be ready for the defendant to sign in the time frame you have given. In our experience, it is not uncommon for real estate transactions to be delayed by banks and we are concerned that this request will simply be followed by additional requests for extensions. From: Haytham Faraj [mailto:haytham@puckettfaraj.com] I understand that they have paperwork that must be endorsed by him and his wife once their loan modification is approved. There is a likelihood that it will not be approved. In the event it is approved, they will have a certain limited period of time to accept the offer or the bank will consider it a rejection. If he were in the San Diego area or somewhere nearby in California, his wife could simply bring it to him. In Texas, it would have be mailed to him and he will have to complete it and mail it back. That process on its own will obviously delay the response. There will also be a high possibility in the first few weeks that his mail may not get delivered right away because his family may not have the exact address or due to initial confusion in the prison mail room as often happens when prisoners first report. Mr. Hamama has prepared himself to report and was preparing his wife in reliance on being assigned to a facility where he might be able to continue to do what is necessary to assist his wife in remaining in their home. He is resolved to completing his sentence. His overarching concern, however, is the welfare of his wife and family. He was fully prepared to report to a facility reasonably close to home. The order to report to Texas disrupted their preparations. From: Martin, Michael C. (USAMIE) [mailto:Michael.C.Martin@usdoj.gov] Mr. Faraj, can you tell me why it would be impossible for him to complete the process from a distance? From: Haytham Faraj [mailto:haytham@puckettfaraj.com] Mr. Martin, I am writing to seek your concurrence on a motion to allow Mr. Martin to report on November 30 rather than September 29. The reason for the delay is so that he and his wife can complete the home loan modification process so that they do not lose their home. We anticipated that he would be assigned to a facility near the San Diego which would have enabled his wife to complete it. He was designated to a facility in Texas. That would make it the process all but impossible to complete. Their bank is telling them it will take 6-8 weeks. Please let me know if you consent. 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 The information contained in this electronic message is confidential, and is intended for the use of the individual or entity named above. If you are not the intended recipient of this message, you are hereby notified that any use, distribution, copying of disclosure of this communication is strictly prohibited. If you received this communication in error, please notify Puckett & Faraj, P.C. at 888-970-0005 or via a return the e-mail to sender. You are required to purge this E-mail immediately without reading or making any copy or distribution. |