MATTHEW D. SEGAL, Assistant
United States Attorney, Attorney for the United States.
JEFFREY B. SETNESS, ESQ.,
California State Bar No. 96773, LEWIS BRISBOIS BISGAARD & SMITH LLP, Las Vegas,
Nevada, Attorneys for Defendant Anthony Ray Manuel.
STIPULATION AND ORDER TO CONTINUE SENTENCING
LAWRENCE K. KARLTON, District Judge.
IT IS HEREBY STIPULATED AND AGREED by and between the Plaintiff UNITED STATES OF AMERICA, by and through Assistant United States Attorney Matthew D. Segal of the United States Attorney's Office for the Eastern District of California, and Defendant ANTHONY RAY MANUEL, by and through Jeffrey B. Setness, Esq. of the law firm of Lewis Brisbois Bisgaard & Smith LLP, that the Judgment and Sentencing date of June 25, 2013 be vacated and a further Status Conference be scheduled for August 13, 2013 based upon the following:
1. Manuel has been diagnosed with coronary artery disease; diabetes with severe neuropathy; and chronic kidney disease Stage IV/diabetic kidney disease. If needed, documents relating to Manuel's medical condition will be provided upon request to the Court.
2. On February 22, 2013, Manuel underwent quadruple bypass surgery.
3. The recovery time for quadruple bypass surgery is quite lengthy. For the last eight weeks since the surgery Manuel was ordered not to lift anything heavier than a coffee cup because his chest is wired together.
4. Vehicle travel except for very short distances is painful and exerting. Manuel cannot drive a vehicle.
5. Manuel has been informed not to exert himself which will fatigue him and may slow his recovery.
6. On Wednesday, May 15, 2013, Manuel will start rehabilitation at Sutter Memorial in Modesto, California three days a week. The rehabilitation program for heart bypass patients will take between eight to twelve weeks and will determine how much exertion Manuel will be able to handle and hopefully will improve his condition.
7. The next assessment of Manuel's medical condition will be in June 2013.
8. Based upon the foregoing, the rehabilitation process will not be completed until sometime in July or August 2013.
Based upon the Stipulation of Counsel, and good ...