SEC Charges Eleven in Stock Manipulation Ring

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MOTION TO MODIFY SCHEDULE FOR PAYMENT OF FINE

NOW COMES, Matthew W. Brown, Defendant, by and through counsel, John R. Garey, Esquire, and moves this Honorable Court for an order to modify the payment schedule for the fine imposed on the Defendant. In support thereof Defendant submits the following:

1. Defendant Brown was sentenced by this Court on May 18, 2011 on counts one, four, five and eight of the indictment to a term of 48 months incarceration, a $50,000.00 fine and a $400 special assessment. The prison terms are to run concurrently.

2. The Court ordered $25,000.00 of the $50,000.00 fine payable within 30 days of the sentence. Thereafter, the remaining balance could be paid during the Defendant’s incarceration and subsequent supervised probation.

3. By order of May 16, 2011, the Court executed a preliminary order of forfeiture for the Defendant’s banking accounts. As a result of the order of forfeiture signed by the Court on May 16, which became final on May 18, Defendant’s disposable cash was depleted immediately following sentencing.

4. Defendant Brown has neither available cash nor disposable assets to abide by the Court’s order regarding the initial payment of $25,000.00.

5. Defendant Brown respectfully asks for an amendment to this order to allow the $50,000.00 fine to be paid while incarcerated and his release on probation.

6. The Government is not opposed to a modification of the schedule of payments for this fine.

WHEREFORE, Defendant Matthew W. Brown respectfully asks this Honorable Court to grant this modification of schedule of payments.

Respectfully submitted,

JOHN R. GAREY, P.A.
/s/ John R. Garey
JOHN R. GAREY, ESQUIRE



Extract -
Doc 61 PDF file
http://viewer.zoho.com/docs/sd3pci