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United States v. Hitachi-LG Data Storage, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Nov 7, 2011
No. CR 11-00724-RS (N.D. Cal. Nov. 7, 2011)

Opinion

No. CR 11-00724-RS

11-07-2011

UNITED STATES OF AMERICA v. HITACHI-LG DATA STORAGE, INC., Defendant.

SIDNEY A. MAJALYA (CA Bar No. 205047) JACKLIN CHOU LEM (CA Bar No. 255293) MANISH KUMAR (CA Bar No. 269493) Antitrust Division U.S. Department of Justice Attorneys for the United States


SIDNEY A. MAJALYA (CA Bar No. 205047)

JACKLIN CHOU LEM (CA Bar No. 255293)

MANISH KUMAR (CA Bar No. 269493)

Antitrust Division

U.S. Department of Justice

Attorneys for the United States

STIPULATION AND [PROPOSED] ORDER FOR EXPEDITED SENTENCING

UNDER L.R. 32-1(b)

COURT: Hon. Richard Seeborg

On September 30, 2011, the United States filed a fifteen-count Information charging Hitachi-LG Data Storage, Inc. ("HLDS") with fourteen counts of violating the Sherman Antitrust Act, 15 U.S.C. § 1, and one count of wire fraud, 18 U.S.C. § 1343. HLDS is scheduled for a change of plea and possible sentencing on November 8, 2011. HLDS will waive Indictment and plead guilty under Fed. R. Crim. P. 11(c)(1)(C). The United States and HLDS have filed a Joint Sentencing Memorandum describing the material terms of the plea agreement and the agreed-upon recommended sentence (Dkt. No. 5). The Plea Agreement has been attached as Exhibit A to the Joint Sentencing Memorandum. The United States has also filed under seal the Declaration of Sidney A. Majalya in Support of United States' and Defendant HLDS's Joint Sentencing Memorandum and the United States' Motion for Departure ("Majalya Declaration") (Dkt. No. 9). IT IS HEREBY STIPULATED AND AGREED as follows:

The United States and HLDS request that the Court sentence HLDS on an expedited basis pursuant to Crim. L.R. 32-1(b) on November 8, 2011, the same date as the scheduled change of plea hearing. The United States and HLDS respectfully submit that the Joint Sentencing Memorandum, the Majalya Declaration, and the Plea Agreement provide sufficient information for the Court to meaningfully exercise its sentencing authority without a presentence report.

Respectfully submitted,

BY: Cristina C. Arguedas

Laurel Headley

Counsel for Hitachi-LG Data Storage, Inc

Arguedas, Cassman & Headley LLP

BY: Sidney A. Majalya

Jacklin Chou Lem

Manish Kumar

Trial Attorneys

U.S. Department of Justice

Antitrust Division
Based on the stipulation of the parties, and for good cause shown,

IT IS SO ORDERED.

Honorable Richard Seeborg

United States District Court Judge


Summaries of

United States v. Hitachi-LG Data Storage, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Nov 7, 2011
No. CR 11-00724-RS (N.D. Cal. Nov. 7, 2011)
Case details for

United States v. Hitachi-LG Data Storage, Inc.

Case Details

Full title:UNITED STATES OF AMERICA v. HITACHI-LG DATA STORAGE, INC., Defendant.

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

Date published: Nov 7, 2011

Citations

No. CR 11-00724-RS (N.D. Cal. Nov. 7, 2011)