UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
May 20, 2010
UNITED STATES, PLAINTIFF
MICHAEL A. DALY, DEFENDANT
The opinion of the court was delivered by: Hon. Ronald M. Whyte
Stipulation and Order Of Bond Exoneration
Now come the parties in this case and stipulate that the five hundred thousand dollar ($500,000.00) real estate bond posted in this case should be exonerated forthwith and request that this Honorable Court order such exoneration as proposed herein.
As reasons therefore, counsel submits the following:
1. Counsel for the defendant has consulted with AUSA Richard Cheng, who assents to this Stipulation.
2. The defendant in this case has reached a restitution agreement with the aggrieved entity (Cisco) and the parties agree that the exoneration of the real estate bond is necessary in order for the defendant to make restitution as agreed.
3. All other terms and conditions of release, including the five hundred thousand dollar ($500,000.00) cash bond posted by the defendant shall remain in effect.
Wherefore, the parties request that this Court exonerate the real estate bond in this case.
Respectfully Submitted, By the Defendant's Attorney,
Liam Scully Liam D. Scully (Pro hac vice) Pavlos Vitali & Scully 142 Main Street, #406 Brockton, MA 02301 (508) 894-0050
Dated: May 6, 2010
Richard Cheng United States Attorney's Office
Order fo the Court
Based on the above stipulation of the parties the Court hereby Orders that the Real Estate Bond posted in this case be exonerated forthwith.
I hereby certify that a copy of the above motion was served on this date to Assistant U.S. Attorney Richard Cheng, United States Attorney's Office, NDCA, 150 Almaden Blvd., Suite 900 San Jose, CA 95113. Liam Scully, May 6, 2010.
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