STIPULATION AND [PROPOSED] ORDER TO CONTINUE DATE TO SURRENDER FOR SERVICE OF SENTENCE

JON S. TIGAR, District Judge.

IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Kyle Waldinger, Assistant United States Attorney, together with counsel for defendant, Claude Kramer III, that the previously set surrender date of June 9, 2017, be continued to January 5, 2018, contingent upon Mr. Kramer being transferred to an "unrepresented position" at his place of employment. In the event that Mr. Kramer is not transferred to an "unrepresented position" he is to surrender to start his prison term no later than June 30, 2017.

Mr. Kramer is currently employed in a vital accounting position by the Alameda-Contra Costa Transit District ("AC Transit"). Mr. Kramer's current position at AC Transit is a position through the American Federation of State, County & Municipal Employees Union, which does not allow its members to retire before the age of 55 (Mr. Kramer is currently 53 years old). However, AC Transit is attempting to transfer Mr. Kramer to an unrepresented position within the company, which would allow Mr. Kramer to retire immediately upon completing 6-months in that position. In doing so, Mr. Kramer could return to work upon completion of his prison sentence, thus, allowing Mr. Kramer to work towards making his victims whole by way of restitution. Moreover, this position would also allow Mr. Kramer to maintain his medical coverage for life.

IT IS SO STIPULATED

ORDER

GOOD CAUSE APPEARING, it is hereby ordered that the June 9, 2017 surrender date be continued to January 5, 2018, contingent upon Mr. Kramer being transferred to an unrepresented position at the Alameda-Contra Costa Transit District.

Should Mr. Kramer not be transferred to an unrepresented position, he is ordered to surrender to start his prison term no later than June 30, 2017