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United States v. Maxzone Vehicle Lighting Corp.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Nov 3, 2011
CASE NO. 11-cr-0653-RS (N.D. Cal. Nov. 3, 2011)

Opinion

CASE NO. 11-cr-0653-RS

11-03-2011

United States of America, Plaintiff. v. Maxzone Vehicle Lighting Corp., Defendant.

Jacklin Chou Lem May Lee Heye Howard J. Parker Kelsey C. Linnett Trial Attorneys U.S. Department of Justice Antitrust Division Jeremy Ostrander (Cal. Bar NX 233489) WHITE & CASE LLP Peter J. Carney (admitted pro hac vice ) Charles C. Moore (admitted pro hac vice ) WHITE & CASE LLP Counsel for Defendant Maxzone Vehicle Li


JEREMY OSTRANDER (Cal. Bar. No. 233489)

jostrander@whitecase.com

White & Case LLP

3000 El Camino Real

5 Palo Alto Square, 9th Floor

Palo Alto, CA 94306

Telephone: (650) 213-0300

Facsimile: (650) 213-8158

PETER J. CARNEY (admitted pro hac vice)

pcarney@whitecase.com

CHARLES C. MOORE (admitted pro hac vice)

charlesmoore@whitecase.com

White & Case LLP

701 Thirteenth Street, N.W.

Washington, D.C. 20005

Telephone: (202) 626-3600

Facsimile: (202) 639-9355

Counsel for Defendant Maxzone Vehicle Lighting Corp.

STIPULATION AND

[PROPOSED) ORDER

FOR EXPEDITED

SENTENCING UNDER

CRIM. L.R. 32-l(b)

Court: Hon. Richard Seeborg

On September 12, 2011, the United States filed a one-count Information charging Defendant Maxzone Vehicle Lighting Corp. ("Maxzone") with participating in a conspiracy to suppress and eliminate competition by fixing the prices of aftermarket auto lights sold in the United States and elsewhere, in violation of the Sherman Antitrust Act, 15 U.S.C. § 1. Maxzone is scheduled for a change of plea and possible sentencing on November 15, 2011 at 2:30 p.m. Maxzone will waive Indictment and plead guilty under Fed. R. Crim. P. 11(c)(1)(C). The United States and Maxzone have filed a Joint Sentencing Memorandum describing the material terms of the Plea Agreement and the agreed-upon recommended sentence. 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 Jacklin Chou Lem in Support of the United States' and Maxzone's Joint Sentencing Memorandum ("Lem Declaration"). IT IS HEREBY STIPULATED AND AGREED as follows:

Maxzone respectfully requests that the Court sentence Maxzone on an expedited basis pursuant to Crim. L.R. 32-1 (b) on November 15, 2011, the same date as the scheduled change of plea hearing. Maxzone respectfully submits that the Joint Sentencing Memorandum, the Lem Declaration, and the Plea Agreement provide sufficient information for the Court to exercise its sentencing authority meaningfully without a presentence report. Under the circumstances set forth in the Joint Sentencing Memorandum, the United States agrees that expedited sentencing of Maxzone is appropriate here and stipulates to the form of this Order,

Respectfully submitted,

Jacklin Chou Lem

May Lee Heye

Howard J. Parker

Kelsey C. Linnett

Trial Attorneys

U.S. Department of Justice

Antitrust Division

Jeremy Ostrander (Cal. Bar NX 233489)

WHITE & CASE LLP

Peter J. Carney (admitted pro hac vice)

Charles C. Moore (admitted pro hac vice)

WHITE & CASE LLP

Counsel for Defendant Maxzone Vehicle Li

Corp.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Honorable Richard Seeborg

United States District Judge


Summaries of

United States v. Maxzone Vehicle Lighting Corp.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
Nov 3, 2011
CASE NO. 11-cr-0653-RS (N.D. Cal. Nov. 3, 2011)
Case details for

United States v. Maxzone Vehicle Lighting Corp.

Case Details

Full title:United States of America, Plaintiff. v. Maxzone Vehicle Lighting Corp.…

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

Date published: Nov 3, 2011

Citations

CASE NO. 11-cr-0653-RS (N.D. Cal. Nov. 3, 2011)