STIPULATION AND [PROPOSED] ORDER TO UNSEAL CASE & TO RESCHEDULE DEFENDANT'S INITIAL APPEARANCE TO A LATER DATE

MARIA-ELENA JAMES, Magistrate Judge.

The United States of America and defendant Brian Peter Stallings, through their undersigned counsel and through this stipulation, respectfully request that the Court unseal the above-captioned case and reschedule Defendant's initial appearance to July 31, 2015, at 9:30 a.m., before Magistrate Judge Maria-Elena James. Defendant's initial appearance is currently set for July 23, 2015, at 9:30 a.m.

On July 9, 2015, Defendant was indicted by a Grand Jury for three counts of making and subscribing false tax returns in violation of 26 U.S.C. § 7206(1), and 11 counts of willful failure to account for and pay over taxes in violation of 26 U.S.C. § 7202. The indictment was sealed by order of the Court. The United States requested that the indictment be placed under seal to permit the United States to execute proper service of the summons before the indictment became public record. On July 10, 2015, Stallings was served with the summons issued in this case. Because the defendant has been served with the summons and has retained attorney Martin Schainbaum, this case should be unsealed.

Moreover, as stated above, the parties also request that the defendant's initial appearance be rescheduled to July 31, 2015. The basis for this request is that Defendant's counsel was only recently retained and has a scheduling conflict. He will be available on July 31, 2015. As such, the parties request that the Court move Defendant's initial appearance to July 31, 2015, at 9:30 a.m. Stipulated and Agreed to By:

[PROPOSED] ORDER

For the reasons stated in the stipulation above, and for good cause shown, IT IS HEREBY ORDERED that:

IT IS SO ORDERED.