Opinion
MICHAEL D. LONG, Sacramento, CA, Attorney for CLARISA ANG.
STIPULATION AND ORDER TO CONTINUE SURRENDER DATE FOR CLARISA ANG
MORRISON C. ENGLAND, Jr., Chief District Judge.
It is hereby stipulated between the parties, Assistant United States Attorney Matthew Yelovich, and Michael Long, attorney for CLARISA ANG, that CLARISA ANG's presently set surrender date of May 1, 2015, should be continued until November 1, 2015. Defendant proffers the following information:
(1) The requested modification of her turn-in date is due to the continuing deteriorating health of her husband and co-defendant Cris Ang. The Angs have provided up-to-date medical documentation to the parties concerning Mr. Ang's recent surgeries and treatment. The court addressed Mr. Ang's request for a modification of his own sentence due to the same health concerns (See ECF documents 387, 388, 389 and 391). Mrs. Ang is still employed by the California Department of Motor Vehicles (DMV) and her employment provides medical coverage for both her and Mr. Ang. Due to the failing health of Mr. Cris Ang, he is no longer able to be employed or financially support himself. Mr. Ang is has undergone recent spinal and lupus-related surgeries that have cost over $200,000. Each specialty doctor visit for related follow-up appointments cost $350. Mr. Ang would not be able to afford the medical care without the DMV insurance. When Mrs. Ang surrenders herself she will lose her job and her health coverage will then terminate. If Mrs. Ang is no longer employed, Mr. Ang will no longer have any medical coverage and he will not be able to pay for any private health care.
(2) Mr. Ang is no longer able to drive a car - his California driver's license was suspended due to his health condition. Mrs. Ang drives him to his medical appointments. Mrs. Ang also provides in-home health care for Mr. Ang on a day-to-day basis, including monitoring and administering his medications.
(3) Clarisa Ang's own health situation has been deteriorating over the past year. She now suffers from diabetes, which has caused diabetic neuropathy (damage to her nerves due to chronic high blood pressure) and hypertension.
Updated medical records for both Cris Ang and Clarisa Ang have been provided to the United States Attorney's office concerning the medical problems discussed in this request.
The Government does not oppose the requested continuance.
We respectfully request that the court order that the presently set surrender date of May 1, 2015, be continued until November 1, 2015, at 12:00 p.m.
ORDER
UPON GOOD CAUSE SHOWN and the stipulation of the parties, it is ordered that the Bureau of Prisons surrender date for CLARISA ANG, presently set for May 1, 2015, at FCI-Dublin be continued to November 1, 2015, at 12:00 p.m. at FCI-Dublin.
IT IS SO ORDERED.