Akram Musa Abdallah background document

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JOSEPH SHEMARIA (Cal. State Bar No. 47311) LAW OFFICES OF JOSEPH SHEMARIA 1801 Century Park East, Suite 2400 Los Angeles, California 90067 Telephone (310) 278-2660 Facsimile (310) 388-0979 Email: [email protected] Attorney for Defendant AKRAM MOUSA ABDALLAH

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

UNITED STATES OF AMERICA,

Plaintiff,

v. AKRAM MUSA ABDALLAH,

Defendant. ____________________________________

) ) ) ) ) ) ) ) ) )

Case No. CR-08-00947-PHX-NVW DEFENDANT’S POSITION RE: SENTENCING Date: November 23, 2009 Court: Hon. Neil V. Wake

TO THE HONORABLE NEIL V. WAKE, UNITED STATES DISTRICT JUDGE, DAVID A. PIMSNER, ASSISTANT UNITED STATES ATTORNEY, BARRY JONAS, DEPARTMENT JUSTICE AND U.S. PROBATION:

Defendant AKRAM MOUSA ABDALLAH, through his attorney of record, Joseph

Shemaria, hereby submits Defendant’s Position with Respect to Sentencing.

Mr. Abdallah reserves the opportunity for his counsel to make additional comments

at the time of the sentencing hearing.

Date: November 11, 2009 Respectfully submitted:

LAW OFFICES OF JOSEPH SHEMARIA By /s/ Joseph Shemaria Attorney for Defendant AKRAM MOUSA ABDALLAH

Case 2:08-cr-00947-NVW Document 73 Filed 11/12/09 Page 1 of 18

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I.

INTRODUCTION

On November 6, 2009, Defendant Akram Mousa Abdallah filed his Objections to

the Presentence Investigation Report (hereinafter PSI). This sentencing memorandum

incorporates by reference all of Mr. Abdallah’s previously lodged objections to the PSI.

Specifically, however the defense reiterates its vigorous objection to Probation’s

recommendation of not accepting the Plea Agreement and, instead, impose an arbitrary

sentence of 46 months. As previously addressed in the defense Objections, with all due

respect, in preparing its report Probation failed two major areas: (1) Probation failed to take

into account the case assessments, judgments and evaluations made by both government

counsel and defense counsel culminating in a vigorously disputed compromise as set forth

in the Plea Agreement; and (2) Probation failed to take into account any of Mr. Abdallah’s

“history and personal characteristics” or, for that matter, any of the other sentencing factors

codified by Congress at 18 U.S.C. §3553(a)(2). Both defendant and his counsel strongly

believe that the totality of mitigating factors warrants a sentence of not more than 18

months which falls within the 18 to 24 month range stipulated to by the parties in the Plea

Agreement.

The purpose of this memorandum and its attached exhibits is to provide an in-depth

portrait of this defendant’s history and personal characteristics, in addition to addressing the

other relevant §3553(a) (2) sentencing factors in order that the Court can better understand

and appreciate, not only how all counsel arrived at the 18 to 24 month provision as

contained in the Plea Agreement, but, further, why it is a fair and just disposition of this

case.

II.

IN THE AFTERMATH OF BOOKER AND GALL, THE SENTENCING

GUIDELINES ARE ONLY ONE OF THE NUMEROUS FACTORS TO BE

CONSIDERED IN ARRIVING AT AN APPROPRIATE SENTENCE


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Before the United States Supreme Court’s decision in United States v. Booker, 543

U.S. 220 (2005), the Sentencing Guidelines were essentially mandatory. Sentencing courts

were required to first determine the applicable guideline range and then, in the majority of

cases, sentence defendants within that range. The Sentencing Guidelines did provide for

technical departures which were sparingly granted, except in cases where the defendant

provided substantial assistance to the Government pursuant to U.S.S.G. §5K1.1. Factors

such as age, education, mental and physical condition, employment record, and family ties

and responsibilities were discouraged as grounds for formal departure [see U.S.S.G.

§§5H1.1 through 5H1.6]. Lack of guidance as a youth [see §5H1.12] was specifically

prohibited as a ground for departure. In addition, “the history and characteristics of the

defendant [18 U.S.C. §3553(a)(1)]” were deemed largely irrelevant in the mandatory,

guideline era.

The Guidelines were implemented in 1987. Their avowed purpose was to promote

uniformity in sentencing in district courts across the country. Yet, too often, the actual

effect of the mandatory guidelines was to prevent district court judges from crafting

individualized justice based on the circumstances of the respective defendant. In essence,

the mandatory guidelines brought about a reliance on a rigid sentencing grid which largely

undermined the sentencing judge’s right to give reasonable consideration to the totality of

factors present under §3553(a)(1) including “the history and characteristics of the

defendant.”

Booker and more recently Gall v. United States, 128 S.Ct. 586, 169 L.Ed.2d 445

(2007), have dramatically revamped the sentencing process.1 The guidelines are now

advisory rather than mandatory. In Gall, the Supreme Court has set forth a deferential

abuse of discretion standard which affords district courts significant latitude in determining

the appropriate sentence. The Supreme Court held:

1 See also Spears v. United States, 555 U.S. (2009), and Nelson v. United States, 555 U.S. (2009), which powerfully reiterate that the guidelines are now truly advisory and that there is no presumption at the District Court level that a guideline sentence is inherently reasonable. See also Rita v. United States, 551 U.S. 338 (2007), and United States v. Tomko, No. 05-4997 (3rd Cir. April 17, 2009).


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We reject, however, an appellate rule that requires

“extraordinary” circumstances to justify a sentence outside the

Guidelines range. We also reject the use of a rigid mathematical

formula that uses the percentage of a departure as the standard

for determining the strength of the justifications required for a

specific sentence.

Gall’s message is that the guidelines truly are just one of the §3553(a) factors to be

considered in arriving at an appropriate sentence. To deviate from the Guidelines, the

circumstances need not be ‘extraordinary;” rather, district court judges now have a mandate

to consider the full range of circumstances involved in a case, and to tailor their sentence

accordingly. The ironclad grid chart contained in the United States Sentencing Guidelines

has been replaced, to a large extent, with the reasoned, individualized judgment of the

sentencing judge. In arriving at an appropriate disposition in the matter at bar, the Court is

asked to give particular consideration to the history and characteristics of Mr. Abdallah and

the overall positive life he has led.

III.

DEFENDANT ABDALLAH’S HISTORY AND PERSONAL

CHARACTERISTICS SUPPORT THE REQUESTED 18 MONTH SENTENCE

The following social history information is presented in the spirit of 18 U.S.C.

§3661 which states:

No limitation shall be placed on the information concerning the

background, character, and conduct of a person convicted of an

offense which a court of the United States may receive and

consider for the purpose of imposing an appropriate sentence.

• Childhood/School

Akram Abdallah, the fifth of eleven children of Mousa and Qatifa Abdallah, was

born on July 5, 1954 in Jericho, Jordan. His mother Qatifa died of complications from

abdominal surgery in 1974. Mousa then remarried Fahima Abdallah with whom he had six


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more children. Mousa was employed as a school principal and was later promoted to the

Jordanian Board of Education.

When Akram was an infant, the Abdallah family moved from Jericho to the capital

city of Amman for the sake of better educational opportunities for their children. Akram’s

family was close-knit and though it was sometimes a challenge to feed so many mouths, he

never lacked for support or proper care.

Akram attended Salah-al-deen School from kindergarten through the eighth grade.

The curriculum was reasonably advanced and Akram studied English literature and

political science as well as physics and electrical engineering. For recreation, he played

soccer, volleyball, and basketball with his brothers and other children in the neighborhood.

After graduating from grammar school in the 1960’s, Akram attended Hasan Albarqawi

High School. He then studied English literature for two years at a Lebanese university.

• Move to United States

In 1976, Akram traveled to New York and stayed with his oldest sister Huda in

Manhattan. He enrolled in community college and worked in the Abdallah family furniture

business. He then settled in Yonkers and opened his own sportswear store in the Bronx in

1978. A few years later he formed a partnership with his brother Ashraf and opened a

second sportswear store, also in the Bronx.

When Akram was not working or spending time with his extended family, he

volunteered at local schools teaching Islamic education and counseling children and their

parents. Akram recalls that he grew to love the diversity of the United States and the

American openness to international cultures.

In 1982, Akram became a United States citizen.

• Marriage and Family

During a visit to Jordan in 1986, Akram was introduce to Areej Qadi by one of his

sisters. Areej’s father worked as a botanist for the agricultural department in Kuwait.

Areej attended college in Amman and graduated from Jordan University with a bachelor’s

degree in religious studies around 1987. Akram and Areej were married the following year.


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Akram and Areej traveled to the United States in 1988 and moved into an apartment

in Yonkers. In order to ease her transition to life in America, Areej attended English

classes and took driver’s education classes. She recalls adjusting fairly quickly to her new

life. Her ready acceptance on the part of Akram’s large extended family helped dispel her

initial feelings of homesickness.

Areej gave birth to their first son Saiaf in May of 1988. Their daughter Aseel was

born three years later by way of a C-section. Prior to the births of her first two children,

Areej returned home temporarily to Amman to be close to her mother and sisters.

• Move to Phoenix

In 1992, Akram relocated to Phoenix, followed by Areej and the children a few

months later. At first Akram worked at a local swap meet selling picture frames, and Areej

stayed home to care for the children.

Areej enrolled at Paradise Valley Community College in 1994 and attained associate

degrees in science, business, and fine art. She supplemented her studies by taking

additional classes at Arizona State University. The couple’s youngest child Ahmad was

born in November of 1996, in Phoenix, Arizona. While Areej was attending school full-

time, Akram rolled up his sleeves and took care of their young children during the school

week while working at the swap meet on the weekends to make ends meet. Areej

transferred to Arizona State University and earned a Bachelor of Science degree in

Computer Information Systems (CIS) in 1998. After an extended job search, she secured a

position at Boeing as a level one software engineer. She was given security clearance and

worked on several classified projects.

Los Angeles area software engineer Samer Abdullah states in an appended letter to

the Court:

She [Areej] has worked on various computer systems that go

into AH-64 Apache helicopters. Her expertise has provided a

great service not only to her community which depends on

Boeing’s income but to the defense of this great country. She


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reminds me of the courageous women who built our country’s

tanks and planes during World War II. Her ability to finish her

computer science degree and work at Boeing was with the

support of her husband. In a concerted effort Akram stayed

home with their youngest son changing diapers, feeding, and

cleaning. His sacrifice to simultaneously run his business and

perform these duties for his family has allowed his wife Areej to

serve this country.

In addition to her regular duties at Boeing, Areej helped lead the company’s

diversity training at seminars where she discussed her religion and culture. These events

were well-received and employees expressed their appreciation for the manner in which

Areej described the many similarities between the Islam faith and the world’s other great

religions. Areej worked at Boeing for 8 years and was promoted to a level two software

engineer. She resigned her post in 2003 and was honored at a large going away party.

In 2000, Akram began working in the telephone sales calling card business. In 2004,

he started his own home-based calling card business, Fiber Optic Communications, which

did fairly well at first. As the pending accusations became public knowledge, however, his

customers began taking their business elsewhere and his company is now practically

defunct.

After leaving Boeing, Areej located a retail space in Mesa, Arizona and began to

renovate it into a café which she named the Double Tree Coffee Shop. An inventive home

cook and baker, she aspired to turn her culinary skills into a small business enterprise. The

café opened in October of 2005 but struggled to develop a sustainable customer base. This,

combined with the health problems Areej later developed, caused Double Tree to close its

doors.

• Community Service

Akram and Areej have spent thousands of hours volunteering at their local Islamic

educational centers and mosques, including the Islamic Community Center of Phoenix


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(ICCP), the Islamic Community Center in Tempe (ICC), and the Islamic Community

Center Mosque (ICCM) of Phoenix. Areej tutored children in math and science and also

baked Middle Eastern pastries for community gatherings. Akram gave lectures to groups of

children and adults about religious tolerance and diversity and helped with a variety of

fundraising activities. He also coached soccer for children.

Family friend and colleague Nasir Attar reports in his letter to the Court:

He [Akram] helps at different organizations that are so diverse

and different from one another. I have seen him help people

from his own faith and race, and then others who had nothing in

common with him. Akram does not know how to not help

people out. It is his nature, and it’s what he loves to do.

As a counselor, Akram guided Islamic-American families who were struggling with

intergenerational conflicts, cultural identity issues, and integration into American society.

Many local organizations, including synagogues, Christian churches, community colleges

and the University of Arizona, have hosted events at which Akram has spoken about the

importance of religious tolerance and understanding and the need to bring diverse

communities together.

Laura Masri, a teacher in the Creighton School District, has known Akram for over

20 years. She writes:

Among the families of the community, Mr. Abdallah has served as a

mediator and counselor. He has created a praiseworthy record of

service of humanity. …he has volunteered for the Bosnian refugees

and the Somalian refugees by finding them employment, housing

and medical care; often times using his very own home as a

temporary solution for their many needs.

…In 2006, Mr. Abdallah participated in the “Interfaith Dialogue,”

an event created with the sole purpose of establishing a respectful


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relationship among religions such as Christianity, Judaism, and

Islam. This remarkable event was noted in the Arizona Republic.

Children

All of the Abdallah children have been good students. They attended local public

schools and the Arizona Cultural Academy, an Islamic private school. Areej has served as

the volunteer principal of the Arizona Cultural Academy for several years. In addition to

her administrative duties, she helps teach language classes and prepares lunches.

Family friend Samir Arikat writes:

Akram’s pride and joy of his life is his family. He is the proud

father of 3 children who are gifted with the intelligence that they

inherited from their father Akram and mother Areej. They are all

honor students and have the utmost respect of their colleagues,

teachers and friends. Akram is happily married to Areej, who is an

incredible woman in her own right. She too is highly

educated…They are a family we consider to be role models for our

Arab-American community.

The Abdallahs’ first-born son Saiaf aspires to be a writer. He is a high school

graduate and has completed two years of community college. At present, he is employed as

a sales associate at Fry’s Electronics, selling computers and computer parts in order to save

money to further his education.

The Abdallahs’ only daughter Aseel has long hoped to become a pediatrician. With

that goal in mind, she applied for and was awarded a scholarship to study pre-med at

Arizona State University. Sadly, her plans were derailed by a terrible car accident in which

her closest friend, Nora Risha, was killed while Aseel was driving.

Nora’s mother, Sarah Risha, describes the tragedy:

I can never forget the darkest day of our lives Wednesday

October 1st, 2008 at 9:20 pm, when we received a call from our

son and his friends informing us that the van our daughter Nora


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was riding in had been hit by a drunk driver. Hosam and I

rushed to the scene at 43rd Avenue and Cactus and found almost

every one of our extended family members of the community

including Mr. Abdallah and his wife and children all at the crash

scene crying like babies after they realized Nora was

pronounced dead at the scene. It is extremely hard for me your

honor to go through this extremely painful memory and type at

the same time, but I genuinely want to share with you how much

we needed the Abdallahs with us at that time and how much

their support and the support of everyone else meant to us.

In the aftermath of the accident Aseel has suffered post-traumatic stress. Following

an academically solid first semester, she began to do poorly in her classes. She is now

seeing a psychiatrist and possible intervention with psychotropic medication is being

evaluated. Aseel volunteers every Monday for several hours at the Banner Day Hospital,

which she finds therapeutic. In order not to jeopardize her scholarship, she has cut back to

two classes this semester and is endeavoring to improve her grades.

The Abdallahs’ younger son Ahmad, age 13, plans to become a video game designer.

He has skipped two grades and is a largely self-taught HTML programmer. In addition to

being a straight “A” student, Ahmad enjoys playing soccer recreationally. He is attending

the Arizona Cultural Academy, where he often volunteers at extracurricular events.

• Health Concerns

A week after the FBI executed the search of their home, Areej had a nervous

collapse. She developed severe tachycardia and hyptertension, which resulted in her being

rushed to the hospital. This collapse was later diagnosed as a stress-induced anxiety attack.

Areej has stated that she feels overwhelmed by the prospect of managing her home and

caring for her three children on her own. Subsequent to this first attack, Areej has

experienced two more anxiety attacks. Due to her state of nervous anxiety, she will

probably not be able to attend her husband’s sentencing hearing. She has also found herself


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overcome by emotions when attempting to write a letter on her husband’s behalf.

Physicians have advised Areej to minimize the stress in her life and to try and avoid

situations that might “trigger” further anxiety attacks.

IV.

SUPPORT FROM THE COMMUNITY

Akram Abdallah has received around 30 letters of support. These letters are

unanimous in attesting to his kindness, generosity, and commitment to helping people from

all backgrounds and religions. A few of the letters are excerpted, and all are attached.

Marwan Ahmad, the owner of a publishing and design business and a father of three,

relates:

He is a man who is always ready to give a helping hand to

people. He is an amazing man who balances between his family,

work, and helping others. Being both part of one Islamic center

we met through mutual friends and got to know this man at

close range… I saw him give lectures, Friday sermons, and

motivate youngsters. What I remember about him is he always

spoke and dressed humbly and met everyone with respect and

open arms. Whether an older man or woman or a child

approached him he was always attentive and gave all his

attention to them. The way he treated children and youth was

exceptional…

… As a business man who has been in this community for many

years and knows hundreds of business owners I have never

heard of a dispute between Akram and any of the business

owners. This told me a lot about his character. He always

prefers to be at the losing end when it comes to differences with


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others. He works with integrity and fairness with others which

has gained him a very respectful reputation in our community.

Mr. Abdallah’s nephew Tariq Abdallah writes:

If there is one person that I would consider my role model, after

my father, it is Uncle Akram. …He is the one that gently

reminds you what you did wrong and explains to you how to

make it right. He is the one that asks God for guidance but also

works hard to find the answers…

…Words cannot describe how many people he has positively

influenced in New York and in Arizona in the past few decades.

No amount of record-keeping can adequately keep track of how

many college students he took in free-of-charge when he himself

was a student at Manhattan College in the 70’s. No measuring

stick can quantify the infinite number of anonymous favors he

did, thankless errands he ran, and impossibly selfless

undertakings he took upon himself for so many people—

strangers and friends alike. I cannot even fathom the emptiness

he will leave behind.

Waleed Najdawi reports:

From the small things to the major ones, Akram has been there

for me. …Not only was he there for his Muslim brothers and

sisters, but he also provided his time and effort to help those

from other religions and cultures. He has assisted people

coming from other countries to find jobs and places to live…

I want to ask you Your Honor, to please give Akram the lowest

sentencing possible. He is a good man who respects people,


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society, and the government. I know him well and I have seen

what a hard working man he is. He works so much just to

provide for his family. They need him, and not just for financial

reasons. They love him, and they have good reason; his family

is his life. I hope he is not kept from them for a long period of

time.

Convenience store owner Mohamed Abunada states:

I have known Mr. Akram Abdallah since 1999; I purchase

phone cards from him. Through the years of doing business

with Mr. Abdallah I have gotten to know him as dependable,

punctual, honest and a man of integrity. I have known Mr.

Abdallah to be an active member of the community, he has been

involved in public appearances to promote interfaith and to

speak about social issues. The past few months have had a

serious and negative impact on Mr. Abdallah’s life and business

due to the ordeal he has been dealing with. Given the hard

economic times that we are in, Mr. Abdallah and his family will

suffer further hardship in the event that he might be taken away

from them.

Another convenience store owner, Sami Eyshou, avers:

I am a Christian man, and for me to be able to have a great

friend like Akram, who is Muslim, to go to, really says a lot

about his character. His faith provides him with great hope for

people and he shows them that by caring for them in numerous

ways. Akram is known for being such a fair person. Because

he works with so many people through business, it is important

for him to keep their trust, and he never lets anyone down. As


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for his personal life, Akram is a big family man. He loves his

family and makes that evident when he talks about them.

Emad Najdawi, the owner of an electric work shop, writes:

This man is willing to do anything to help others out, and there

isn’t an ounce of negativity or ruthlessness in him. I hope that

he is given the compassion in sentencing that he deserves;

because Akram himself, is a very compassionate person. Thank

you, and please strongly consider lessening his sentence for the

sake of his family, friends, and society.

Ismael Suwwan, restauranteur and handyman, comments:

He has helped me greatly in my time of need especially when he

kept referring customers to me… I’m a professional handyman

and I know more than anyone that word of mouth is the best

advertisement when it comes to fixing things around a person’s

home, and I have Mr. Abdallah to thank for that. He has helped

me get many jobs throughout the valley whether its tile,

carpeting, painting or construction.

Gas station owner Philip Marogi observes:

He goes out of his way to help the unfortunate with no returns

expected. I was present many times when he was trying to find

a job or shelter for someone or helping a family in need or even

a customer that needs a boost to his car battery or an old woman

unable to pump her gas.

Fares Alzubidi owns the Picture Perfect Gallery. He makes the following plea:

Mr. Abdallah is a motivated man of numerous talents and

considerable self discipline. He is fun-loving, likable,

enthusiastic, trusting and trustworthy. Simply, he is the most

wonderful human being I have met in my life. This is a fact.


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Our society needs more people like him. His wife, children, and

many people in our society will suffer from him being away. So

please…do not lengthen the term of his imprisonment... We

need him as well as others do. We would like him to be free as

soon as possible.

Attorney Steve Tidmore writes:

Akram is a deeply sensitive, caring, and loving man. He has

demonstrated immense compassion and empathy to the plight of

his daughter, her friends, the members of his community, and

even the individuals whose malfeasance and nonfeasance

contributed to and caused his daughter’s injuries and the death

of her friend.

I come from a Christian tradition… The principles that most

clearly resound in Christ’s teachings are redemption,

forgiveness, mercy, grace, reconciliation, and restitution. Christ

does not teach retribution and punishment.

Although Akram comes from an Islamic tradition, his conduct,

in my experience, has exemplified the “values” in Christ’s

teachings…

V.

THE §3553(A)(2) FACTORS SUPPORT THE

REQUESTED SENTENCE OF 18 MONTHS

18 U.S.C. §3553(a)(2) directs that in arriving at an appropriate sentence, the need for

just punishment, adequate deterrence and public safety all must be considered. Yet it

important to keep in mind that in a Federal criminal matter, punishment is hardly limited to

whatever term of incarceration may ultimately be imposed. Quite the contrary, the


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punishment, in a real sense, begins the day when a defendant is first informed that a

criminal investigation is underway and continues long after any eventual term of

imprisonment is completed.

In this instance, the collateral consequences of Mr. Abdallah’s arrest and conviction

have been profound. His name his been blackened in his community and his calling card

business has been decimated. This once proud and popular community leader is now seen

as “radioactive” -- persona non grata in the eyes of many. His wife, who has also been a

highly respected member of the community, is now a mere shadow of her former self. She

has experienced a series of nervous breakdowns accompanied by hypertensive reactions and

tachycardia. She is now reduced to a state of fragility that does not bode well for her ability

to care for her home and three children during the period of her husband’s absence.

Any Federal felony conviction results in the loss of innumerable civil rights

including the right to vote, the right to hold public office, the right to serve on a jury, the

right to possess a firearm, and the right to social security benefits. The “civil death” that

convicted felons experience long after they pay their debt to society can hardly be

exaggerated. Due to the nature of his particular offense, Akram Abdallah will not only

forfeit the above-listed rights; in addition, he will forever be linked, however peripherally,

in the minds of many as an individual who raised funds for the Holy Land Foundation and

thus played a part, albeit inadvertently, in activities thought to be counter to the security of

this nation.

This onus will be a millstone around his neck for years to come. He will not only

face myriad practical problems including real difficulty, based on his felony conviction, in

finding gainful employment but will also feel shamed and disgraced for the rest of his life.

This is a situation that, sadly, will not only affect him and his wife but will also reflect badly

on their three children.

The need for extensive punishment in the form of incarceration is vastly reduced

based on the real ongoing punishment, both practical and emotional, that this defendant and

his family have been and will continue to experience for the foreseeable future. For these


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reasons, a sentence of 18 months, at the low end of the parties’ agreed upon 18-24 month

sentencing range, would be more than adequate to fulfill the need for confinement as an

element of Mr. Abdallah’s overall punishment.

The requested 18 month sentence would also satisfy the need for the sentence to

afford ample general deterrence. A term of 18 months will adequately convey the message

that making false statements when questioned by government officials is not permissible.

With respect to individual deterrence and incapacitation, the reality is that Mr. Abdallah is

not a threat to society and thus a term of imprisonment is not required for purposes of the

community’s safety. The need for just punishment and adequate deterrence, both specific

and general, will be satisfactorily addressed by the requested 18 month sentence, to be

followed by a multi-year period of Supervised Release with all of the oversight and

restrictions inherent to that process. Combined with the manifold painful consequences

that Mr. Abdallah and his family have endured collateral to this investigation and

prosecution, it is submitted that a sentence of 18 months at the low end of the stipulated

range would be “sufficient but not greater than necessary” to comply with the sentencing

factors set forth in 18 U.S.C. §3553(a).

VI.

CONCLUSION

In arriving at a just and reasonable sanction for Akram Abdallah, his lifetime of

good deeds and care and concern for the community should be given appropriate weight.

The thirty character reference letters that have been received on his behalf offer a detailed

description of a man of real character with a profound commitment to religious tolerance

and the performance of tangible good works.

It is clear that Akram Abdallah is singularly devoted to his family and the

community he has always cared for. He is neither a bigot nor a zealot, and he has enriched

the lives of many hundreds if not thousands of individuals of every religious and ethnic

persuasion. It is hoped that like bread upon the waters, his many good deeds and acts of


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personal kindness will weigh in his favor, and that the Court may factor in the above

mitigating circumstances in determining the appropriate punishment.

Date: November 11, 2009 Respectfully submitted:

LAW OFFICES OF JOSEPH SHEMARIA By /s/ Joseph Shemaria Attorney for Defendant AKRAM MOUSA ABDALLAH


Documents

Akram Musa Abdallah background document