Opinion
Case No.: CR 10-0171 RS
06-01-2012
UNITED STATES OF AMERICA, Plaintiff, v. INSOO KIM, Defendant.
MARTIN A. SCHAINBAUM (CSBN 37257) BRYANT W.H. SMITH (CSBN 250035) ANDREW ALLEN (CSBN 269502) Attorneys for Defendant
MARTIN A. SCHAINBAUM (CSBN 37257)
BRYANT W.H. SMITH (CSBN 250035)
ANDREW ALLEN (CSBN 269502)
Attorneys for Defendant
STIPULATION AND [PROPOSED]
ORDER TO MOVE SURRENDER DATE
TO OCTOBER 22, 2012
STIPULATION
The Court ordered Defendant to surrender himself to the custody of the U.S. Marshalls on August 15, 2012. The United States and Defendant, through undersigned counsel, hereby stipulate and agree for Defendant's surrender date to be moved from August 15, 2012 to October 22, 2012.
In support of the parties' stipulation, Defendant states that:
1. An October 22, 2012 surrender date is likely to be less damaging to Melody Painting's business than the previously-ordered August 15, 2012 surrender date.
2. The August 15, 2012 surrender date would be a hardship for Defendant because of its impact on Defendant's work at Melody Painting during the summer season. Accordingly, the October 22, 2012 surrender date would lessen the impact on the business of Melody Painting.
Respectfully submitted,
MELINDA HAAG
United States Attorney
_________________________
THOMAS MOORE
Assistant United States Attorney
MARTIN A. SCHAINBAUM
A Professional Law Corporation
_________________________
MARTIN SCHAINBAUM
Counsel for Plaintiffs
ORDER
Based on the above agreement and stipulation of the parties to this action, and good cause appearing therefor, it is hereby
ORDERED that Defendant surrender himself to the custody of the U.S. Marshall Service on October 22, 2012, in lieu of the previously-ordered August 15, 2012 surrender date.
_________________________
RICHARD SEEBORG
United States District Judge