SEC Charges Eleven in Stock Manipulation Ring

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4. Based on information available to the government as of the date of this memorandum, including information provided by the defendant, the government and defendant stipulate that for the purposes of sentencing on the indictment, the loss attributable to the defendant under U.S.S.G. 2B1.1, including relevant conduct as defined in U.S.S.G. 1B1.3, is in excess of $1,000,000.

02/17/2010 26 MEMORANDUM of PLEA AGREEMENT as to Matthew W. Brown (nms) (Entered: 02/17/2010)

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