STIPULATION AND [PROPOSED] ORDER TO RESET SENTENCING HEARING

WILLIAM B. SHUBB, District Judge.

The United States of America, through its counsels of record, Benjamin B. Wagner, United States Attorney for the Eastern District of California, and William S. Wong, Assistant United States Attorney, and defendant HUY CHI LUONG, through his counsel, John Balazs, Esq., stipulate and agree to the following revised sentencing hearing currently set for May 13, 2013, at 9:30 a.m. to a new sentencing hearing date of May 20, 2013, at 9:30 a.m.

The defendant's reply to the Government's sentencing memoranda raises several issues that necessitated the need for the government to obtain a transcript of the defendant's sentencing hearing before Judge Patel in the Northern District of California; the presentence report that was filed in the Northern District of California; and the Northern District of California's indictment charging RICO offenses. The government was able to obtain the aforementioned documents just yesterday, May 8, 2013, with the assistance of defendant's counsel and the AUSA in the Northern District of California. The government needs additional time to adequately and effectively respond to the issues raised in the defendant's reply to the Government's sentencing memoranda.

Counsel for the defendant was contacted and has no objection to this request to change the sentencing hearing date to May 20, 2013.

ORDER TO RESET SENTENCING HEARING

For the reasons set forth above, the sentencing hearing date is now changed to May 20, 2013, at 9:30 a.m.