IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
December 22, 2011
UNITED STATES OF AMERICA,
SHANNON FORD, ET AL.,
The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
BRUCE LOCKE (#177787) Moss & Locke 800 Howe Avenue, Suite 110 Sacramento, CA 95825 (916) 569-0667 (916) 569-0665 fax Attorneys for SHANNON FORD
STIPULATION AND [PROPOSED] ORDER CONTINUING THE DATE FOR DEFENDANT'S SURRENDER FROM JANUARY 6, 2012 TO FEBRUARY 24, 2012
Stipulation The defendant, Shannon Ford, by and through her attorney, Bruce Locke, and the United States, by and through its attorney, John Vincent, hereby stipulate that the date that Ms. Ford shall self-surrender to the prison designated by the Bureau of Prisons should be continued from January 6, 2012 to February 24, 2012.
The reason for delaying the date for self-surrender is that Ms. Ford's seven year old daughter, Rylin, has recently been diagnosed with a tumor on her parathyroid gland. That tumor causes her to fall asleep in class, to fall into spells, and to lose urinary continence. According to the surgeon, the tumor puts Rylin at risk of associated complications including irregular hearat rhythm, seizures, kidney stones, poor gastrointestinal motility and muscle and bone pain. Rylin is now scheduled for surgery to remove the parathyroid gland on January 9, 2012 at the Lucile Packard Children's Hospital at Stanford. Ms. Ford's family doctor believes that the possibility that her mother will not be there for the surgery is causing Rylin to have anxiety that may complicate putting her under general anesthesia. The new date for Ms. Ford's self-surrender is based upon the Doctor's opinion that it will take Rylin 4 to 6 weeks to recover from the surgery.
Mr. Vincent has authorized Mr. Locke to sign this Stipulation and Proposed Order for him.
IT IS SO ORDERED.
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