SEC Charges Eleven in Stock Manipulation Ring

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OCR extract - GOVERNMENT'S MOTION TO SCHEDULE SENTENCING

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Criminal Action No. 09-46-SLR

UNITED STATES OF AMERICA
Plaintiff,

v.

MATTHEW BROWN,
Defendant.

GOVERNMENT'S MOTION TO SCHEDULE SENTENCING

COMES NOW the United States of America, by and through Rod J. Rosenstein, United States Attomey for the District of Maryland, and Keith M. Rosen and Shannon T. Hanson, Special Assistant United States Attomeys, and respectfully requests that the Court schedule sentencing in this matter. In support thereof, the govemment states as follows:

1. On January 26, 2011, the Court conducted a teleconference with counsel in this matter. At that time, the government informed the Court that it may be appropriate to proceed to sentencing in this matter. In the interim, the Court scheduled a status conference for March 28, 2011, and directed the government to advise the Court at such point that the sentencing should be calendared.

2. On January 10, 2011, the Office of the Deputy Attorney General approved the recusal of the United States Attorney’s Office for the District of Delaware from this matter, and assigned the matter to the United States Attomey’s Office for the District of Maryland. The Deputy Attorney General permitted Delaware AUSAs Keith M. Rosen and Shannon T. Hanson to be appointed as Special Assistant United States Attorneys in the District of Maryland to assist in the further prosecution of this case. SAUSAs Rosen and Hanson were sworn in by the District of Maryland United States Attmey’s Office on February 2, 2011.

3. The government is prepared to proceed with the sentencing of Mr. Brown, and requests that the Court schedule the sentencing hearing at this time.

4. On February 16, 2011, counsel for the government conferred with USPO Walter Matthews, who is the assigned Pre-Sentence Officer in this case. Mr. Matthews advised that his office would require ninety (90) days to complete the pre-sentence process. Accordingly, the government respectfully requests that the Court schedule sentencing at its earliest convenience on or after May 16, 2011.

5. In light of the forgoing, the government submits that the March 28, 2011, status conference is no longer necessary.

6. A proposed Order is attached.

Respectfully submitted,

ERIC H. HOLDER, JR.
Attorney General of the United States

ROD J. ROSENSTEIN
United States Attorney

BY:
Keith M: Rosen WW
Shannon T. Hanson
Special Assistant United States Attorneys
Dated: February 16, 2011

Doc 48 PDF file
http://www.docstoc.com/docs/71777541/USA-v-Brown-Doc-48-Filed-16-Feb-11