RONALD HOLMES' UNOPPOSED MOTION TO CONTINUE SELF-SURRENDER DATE TO AUGUST 15, 2014 AND ORDER THEREON

LARRY R. HICKS, District Judge.

Defendant Ronald Holmes, by and through his counsel, Michael L. Lipman and Barbara H. Murray of Duane Morris LLP, respectfully submits the following Unopposed Motion to Continue Self-Surrender Date to August 15, 2014. In support of this motion, Mr. Holmes represents that:

1. As set forth in the Judgment imposed on March 26, 2014, Mr. Holmes is required to surrender for service of his 37 month sentence before 12 p.m. on Friday, May 30, 2014.

2. As set forth in the attached letter from Chinyere Okeke, M.D., Mr. Holmes has been diagnosed with a severely arthritic left ankle. (Exhibit A.) According to Dr. Okeke, "this condition would continue to deteriorate over the next 3 years without an ankle fusion surgical procedure. . . . If Mr. Homes waited for a period of 3 years this procedure could become more complicated since he already has type 2 diabetes." According to Dr. Okeke, the procedure can be scheduled for the week of June 5, 2014, followed by eight to twelve weeks of recovery and rehabilitation. As a result, Mr. Holmes requests a continuance of his self-surrender date to August 15, 2014, which is ten weeks after the proposed surgery.

3. According to Assistant U.S. Attorney Daniel Schiess, the government agrees to remain silent on this request. (Declaration of Barbara Howe Murray, para. 2.)

4. Mr. Holmes will file an acknowledgment of the new self-surrender date.

For the foregoing reasons, Mr. Holmes requests a continuance of his self-surrender date from May 30, 2014 to August 15, 2014.

DECLARATION OF BARBARA H. MURRAY

I, Barbara H. Murray, declare as follows:

1. I am a Special Counsel with Duane Morris LLP, attorneys for Defendant Ronald Holmes in this matter.

2. On May 23, 2014, I spoke with Assistant U.S. Attorney Daniel Schiess about Mr. Holmes's request to continue his self-surrender date to August 15, 2014. AUSA Schiess informed me that the government agrees to remain silent on Mr. Holmes's request.

3. On that basis, Defendant Ronald Holmes requests that he surrender for service of sentence at the institution designated by the Bureau of Prisons before 12 p.m. on Friday, August 15, 2014, rather than on May 30, 2014.

I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct to the best of my knowledge and belief.

IT IS SO ORDERED. NO FURTHER EXTENSIONS will be granted.

EXHIBIT A