MELINDA HAAG, (CSBN 132712), United States Attorney, J. DOUGLAS WILSON, (DCBN 412811), Chief, Criminal Division, ADAM A. REEVES, (NYSB 2363877), ROBERT S. LEACH, (CABN 196191), Assistant United States Attorneys, San Francisco, California, Attorneys for Plaintiff.
Carl H. Loewenson, Jr., George C. Harris, Esq., MORRISON & FOERSTER, LLP, Counsel for Maher Kara.
Ismail Ramsey, Esq., Miles Ehrlich, Esq., RAMSEY & EHRLICH LLP, Counsel for Mounir Kara.
STIPULATION AND [PROPOSED] ORDER
EDWARD M. CHEN, District Judge.
WHEREAS, on July 6, 2011, Maher Kara pled guilty and agreed to cooperate with the government's ongoing insider trading investigation;
WHEREAS, on July 13, 2011, Mounir Kara pled guilty and agreed to cooperate with the government's ongoing insider trading investigation;
WHEREAS, on September 1, 2011, Bassam Yacoub Salman was indicted on charges related to this insider trading scheme;
WHEREAS, on May 29, 2012, Karim Iskander Bayyouk was indicted on charges that are also related to this case;
WHEREAS, the Court scheduled trial in United States v. Salman to begin on July 19, 2013;
WHEREAS, the Court scheduled trial in United States v. Bayyouk to begin on August 26, 2013;
WHEREAS, the parties (1) now anticipate that Maher Kara and Mounir Kara will both be witnesses for the government in the upcoming trials pursuant to their respective cooperation agreements; (2) request that the sentencing hearings for their respective cases be adjourned until after the trials so they may complete their cooperation; and (3) request that the status conference in these cases therefore be postponed to a date that is convenient for the Court in October 2013.
THEREFORE, it is hereby stipulated by and between the parties, through their respective counsel of record, that the status conference scheduled for June 19, 2013 be continued to a date convenient to the Court in October 2013 and that the time from June 19, 2013 to a date that is convenient for the Court in October 2013 shall be excluded in computing the time within which the trial of the offense alleged in the Indictment must commence under Title 18, United States Code, Section 3161 for defendants Maher Kara and Mounir Kara.
On the basis of material submitted ...