STIPULATION AND [PROPOSED] ORDER CONTINUING RESTITUTION HEARING Modified

EDWARD M. CHEN, District Judge.

The United States, by and through its counsel AUSAs Benjamin Kingsley and Robin Harris, and the defendant William Wise, by and through his counsel Paul Wolf and James Stevens, stipulate and agree as follows:

1. At the parties' appearance on February 4, 2015, the Court set April 22, 2015 for a restitution hearing in this case.

2. On April 15, 2015, this Court found that restitution is mandated in this case and will be ordered in an amount to be determined. Because the data regarding restitution are voluminous, at that time, the parties requested and this Court granted a continuance of the restitution hearing until May 27, 2015.

3. Defense counsel has been diligently reviewing data provided by the government, and comparing it to amounts paid as part of the SEC action in Texas. Because of the volume of materials, the defense needs more time. The government has no objection to providing the defense with additional time to do so.

4. Accordingly, for the reasons set forth above, the parties jointly stipulate and agree that the restitution hearing be continued until July 8, 2015. The parties will attempt to resolve the restitution amount via stipulation in advance of that hearing, or otherwise will submit briefs to the Court by July 1, 2015, regarding their respective positions on appropriate restitution. The parties request that the Court order that Mr. Wise continue to be housed in the Northern District of California so that he can be present for any future restitution proceedings.

SO STIPULATED.

[PROPOSED] ORDER

The restitution hearing set for May 27, 2015 at 2:30 p.m. is continued to July 8, 2015 at 2:30 p.m. The Court orders that defendant continue to be housed in the Northern District of California so that he can be present for any future restitution proceedings. Briefs due July 8, 2015.

IT IS SO ORDERED.