Opinion
No. S-11-CR-0292 EJG
08-09-2011
UNITED STATES OF AMERICA, Plaintiff, v. ROBERT ROSE, Defendant.
Benjamin B. Wagner United States Attorney By: RUSSELL L. CARLBERG Assistant U.S. Attorney Christine A. Varney Assistant Attorney General By: ANNA T. PLETCHER RICHARD B. COHEN TAI MILDER Trial Attorneys U.S. Department of Justice Antitrust Division Ismail Ramsey Mary Kelly Persyn Attorneys for Defendant Robert Rose
BENJAMIN B. WAGNER
United States Attorney
RUSSELL L. CARLBERG
Assistant U.S. Attorney
ANNA T. PLETCHER
RICHARD B. COHEN
TAI MILDER
Trial Attorneys
U.S. Department of Justice
Antitrust Division
STIPULATION AND [PROPOSED]
ORDER RESETTING DATE FOR ENTRY
OF PLEA
THE PARTIES HEREBY STIPULATE AS FOLLOWS:
On July 13, 2011, the United States Attorney filed an Information charging defendant Robert Rose with one count each of (1) bid rigging, in violation of Title 15, United States Code, Section 1, and (2) Conspiracy to Commit Mail Fraud, in violation of Title 18, United States Code, Section 1349. On July 13, 2011, the Hon. Edward J. Garcia ordered the Rose case related to the matter of United States v. Ghio, Cr. S-10-0144 EJG, and other cases. Based on representations of the government concerning availability of the parties, the Court ordered the Rose matter be set for initial appearance and entry of plea on August 12, 2011, at 10 a.m..
Due to an issue that arose as the Court issued its order, the August 12 date became unavailable for defense counsel. Accordingly, the parties now respectfully request that the Rose matter be re-set for initial appearance and entry of plea on September 23, 2011, at 10 a.m.. This date is agreeable to all parties. Moreover, Colleen Lydon, Courtroom Deputy and Judicial Assistant to the Court, has indicated that this is an available day and time.
Respectfully Submitted,
Benjamin B. Wagner
United States Attorney
By: RUSSELL L. CARLBERG
Assistant U.S. Attorney
Christine A. Varney
Assistant Attorney General
By: ANNA T. PLETCHER
RICHARD B. COHEN
TAI MILDER
Trial Attorneys
U.S. Department of Justice
Antitrust Division
Ismail Ramsey
Mary Kelly Persyn
Attorneys for Defendant Robert
Rose
For the reasons stated above, it is hereby ordered that the initial appearance and entry of plea for defendant Robert Rose, currently set for August 12, 2011, is vacated.
Defendant Rose's initial appearance and entry of plea are ordered re-set for September 23, 2011, at 10 a.m., in Courtroom #8, 13th Floor, and the defendant is ordered to appear.
IT IS SO ORDERED.
HON. EDWARD J. GARCIA
UNITED STATES DISTRICT JUDGE
Signed with permission of counsel via email.