STIPULATION AND [PROPOSED] ORDER TO SET CHANGE OF PLEA HEARING

RICHARD SEEBORG, District Judge.

The United States of America, by government counsel, and the defendant, by and through his counsel, Ivan Bates, Esq. hereby notify the Court that the parties have reached a Plea Agreement to the charges contained in the Criminal Information filed June 22, 2015, in the captioned case, to wit: extortion, money laundering with predicate specified unlawful activities of both wire fraud and theft of government property, and obstruction of justice. The parties hereby stipulate and request that the Court schedule a change of plea hearing for the defendant to enter his guilty pleas at 2:00 p.m. the afternoon of July 1, 2015. Government counsel understands from the Courtroom Deputy that the Court may be able accommodate this special setting given the number of parties traveling from the East Coast.

The government will lodge a copy of the fully executed Plea Agreement with the Court directly to chambers later today for the Court's review.

Further, the parties request the Court order that the arraignment on the Criminal Information that was filed June 22, 2015, be calendared before the Duty Magistrate on July 1, 2015 at 9:30 a.m.

SO STIPULATED:

PROPOSED ORDER

IT IS HEREBY ORDERED that:

(1) The defendant will be arraigned on the charges in the Criminal Information in the captioned case before the Duty Magistrate on July 1, 2015 at 9:30 a.m.;

(2) The defendant will appear before this District Court on July 1, 2015 at 2:00 p.m. for a change of plea hearing; and

(3) The government shall lodge a copy of the fully executed Plea Agreement with the Court by providing it directly to chambers.