FROM: Kiyanta Hammond, on behalf of,
____ January, 2021.
TO: FCI Pekin
2600 S. Second St.
Pekin, IL 61554.
RE: LETTER OF compassionate RELEASE; in the matter United States of America v. Trainer Alexander, United States District Court, Eastern District of Michigan, Southern Division, Case No. 11-20180
I am writing this letter on behalf of the above-named prisoner, who is currently held at the ________. This is a request for a motion under 18 U.S.C. §4205(g) based on extraordinary or completing circumstances under 18 U.S.C. §3582(c)(1).
Mr. Tranier Alexander is a 37 year old male, 26yrs old at time of offense and 28yrs old at time of sentencing.
I am Mr. Tranier Alexander’s sister. I can attest that he is a good man of noble character. He, acting on misguided advice, made some bad decision with the aim of fending for his family. Something he has since regretted.
SUMMARY OF THE MOTION.
I am asking that you consider Mr. Tranier Alexander’s early release on compassionate grounds based on the following; the update on the First and Second Step Acts where the sentencing for the charge against him is no longer applicable, on health grounds as he has been infected with Covid-19 twice and has since lost his sense of taste and smell (find attached copies of medical report), and he has a sick elderly father who needs care and support (find attached copies of father’s medical report). Mr. Tranier Alexander seeks Release on Compassionate grounds to be able to give his father care during his illness.
Additionally, Mr. Tranier Alexander has lost mother and siblings who died since his incarceration, one of his siblings was his co-accused Dwaine Danair Alexander (“Dwaine”) who died months after release from prison (find attached copies of the obituaries).
I also ask for consideration for an application for Temporary Release. It is difficult to see that Mr. Tranier Alexander can be kept socially secluded and receiving the adequate medical attention and care while in custody.
Mr. Tranier Alexander’s incarceration, his brother’s death and all that he has gone through has inspired the establishment of the Blossoming Beginnings Human Services (BBHS). This is a non-profit organization that offers support for the youth and families who have been affected by the criminal justice system in Phoenix. Upon his release, Mr. Tranier Alexander shall first be counselled by the BBHS team then become a mentor to speak with the youth in an effort to ensure early prevention of drug related crimes in Phoenix.
Mr. Tranier Alexander agrees to supervised release and shall, where necessary work with the justice system when his presence is required. Upon his release he shall live with his fiancé Ms. Brianna Hatchett. I intend to get married and he would be placed on my health insurance.
The fiance’s address is:
4238 E Tyson St
Gilbert, AZ 85295
STATEMENT OF FACTS.
Mr. Tranier Alexander was sentenced on or about March 30, 2012 to a term of 222 months for non-violent drug related offenses. He is scheduled to be released on 25th March 2028. He has since served more than 128 months. His co-accused included his brother Dwaine Danair Alexander (“Dwaine”) have all been released. Dwaine Danair Alexander (“Dwaine”) died months after being released from prison. This affected Mr. Tranier Alexander emotionally, psychologically and mentally since the two have always been close since their childhood. Mr. Tranier Alexander, having been so affected by his brother’s death has often expressed that he wish he was there for him. He has vowed not to go back to his old ways as an honor and in memory of his brother.
Reasons to warrant this motion;
- Legal grounds on his sentence.
Mr. Tranier Alexander committed a drug related offense. However, the drugs were never sold to the school children and neither was the crime committed with the school premises (Find attached case files). The Defendant has served over 128 months of his 222 month term. This means that he has served more than 10 years of his term and he qualifies for Compassionate Release as provided for under BOP Program Statement 5050.50 and U.S.S.G §1B1.13. He had previously in 2004 been on a short probation.
The Defendant has, during the time of incarceration, been an inmate of good moral character, has worked alongside his prison mates peacefully and has not in any given time been a bother to the prison authority. Additionally, in light of 18 U.S.C § 3553, an inmate can be considered for early release if it is proven that he has been of good character during the time served. He has no other felony against him and there are no unresolved detainers.
- Urgent family needs.
Furthermore, BOP Program Statement 5050.50 and U.S.S.G §1B1.13 recognizes that an inmate may be released on Compassionate Release where they prove that they have urgent family matters that really need their attention. Mr. Tranier Alexander’s father is currently very ill. Before his death Mr. Dwaine Danair Alexander (“Dwaine”) and I took to caring for our father. However, after the death of Mr. Dwaine Danair Alexander (“Dwaine”), I am the only family member available to look after my father. I have four children who I also take care of myself and this responsibility is taking a toll on me. Mr. Tranier Alexander should be considered for early release on Compassionate grounds to go home and help take care of his ailing father. (Find attached copies of Father’s medical reports).
Also affected by this are Mr. Tranier Alexander’s children aged between 13-15years. They love their grandfather dearly and are emotionally and psychologically affected by his illness. Mr. Tranier Alexander should be released early to offer his children emotional support during this trying family moment.
- Medical condition.
Additionally, Mr. Tranier Alexander has suffered two covid-19 infections. He has been so affected since he has since lost his sense of taste and smell. Under BOP Program Statement 5050.50 and U.S.S.G §1B1.13 inmates qualify for early release on compassionate grounds if they are unwell and where the said illiness is contagious. Covid-19 care requires that the patient be sechuled from the rest to avoid infecting the rest. And even upon recovery, the person should remain separated from the rest to prevent reinfection since their immunity is still low. The fact that Mr. Tranier Alexander has contracted the infection twice already means that he is highly susceptible to future reinfections. Mr. Tranier has really suffered due to this virus and we request that he be released so that we can afford him specialized care and attention.
Given the current review of mandatory minimum sentences, Mr. Tranier Alexander sets forth that his release would not minimize the severity of the offense as he will have 8 years of supervised release and does not object to that. The Supervised Release has extremely stringent conditions and Mr. Alexander is prepared to abide by those conditions.
As demonstrated above, there are enough sufficient reasons that warrant the early release of Mr. Tranier Alexander on compassionate grounds. I am worried over Mr. Tranier Alexander’s health and the health of our father. I am urging you to take into consideration of his current medical condition and take the necessary step to protect him and those around him. Also take into consideration his father’s urgent need for care and the fact that Mr. Tranier Alexander can provide the much needed care and attention. Lastly, kindly take into consideration Mr. Tranier Alexander’s teenage kids who have really suffered so much loss of family members and the pain of seeing their grandfather ailing as he is. They are kids who need guidance lest they go astray, guidance that Mr. Tranier Alexander should offer.
Respectfully submitted by,
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