Opinion
No. CR 12-00486-WHA
03-11-2013
UNITED STATES OF AMERICA, Plaintiff, v. JOHN KIERAN HYNES, Defendant.
MELINDA HAAG (CABN 132612) United States Attorney MIRANDA KANE (CABN 150630) Chief, Criminal Division THOMAS MOORE (ALBN 4305-O78T) Assistant United States Attorney Chief, Tax Division Attorneys for United States of America
MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
THOMAS MOORE (ALBN 4305-O78T)
Assistant United States Attorney
Chief, Tax Division
Attorneys for United States of America
STIPULATION TO DISCLOSE GRAND
JURY INFORMATION AND [PROPOSED]
ORDER
For the reason that the trial of this matter is set for March 25, 2013, and because the United States and the defendant are preparing this matter for trial and because they are also attempting to resolve this matter,
It is hereby stipulated by and between Plaintiff United States of America and Defendant John Kieran Hynes, through their respective counsel, as follows:
1. Pursuant to 18 U.S.C. § 3500 the Untied States may, at this time, disclose any Rule 6(e) grand jury testimony of its anticipated trial witnesses to defendant's counsel for use in the preparation and trial of this matter, and at the conclusion of the trial of this matter or upon entry of a guilty plea in this matter, defendant's counsel shall destroy such information; and
2. In the event the defendant enters a guilty plea in this matter, the United States Attorney may disclose any grand jury information in this matter to the Internal Revenue Service for its use in the determination and litigation of any civil tax obligations arising from the investigation and prosecution of this matter.
MELINDA HAAG
United States Attorney
______________
JOHN YOUNGQUIST
Attorney for the Defendant
______________
THOMAS MOORE
Assistant United States Attorney
PURSUANT TO STIPULATION, IT IS SO ORDERED.
______________
UNITED STATES DISTRICT JUDGE
William Alsup