Beruflich Dokumente
Kultur Dokumente
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22 The United States and TomorrowNow, Inc. ("TomorrowNow") have reached a proposed
23 resolution in the above-captioned matter. Specifically, TomorrowNow will waive indictment and
25 Computer, with Intent to Defraud and Obtaining Something of Value, in violation of 18 U.S.C.
27 § 506(a)(1)(A) and 18 U.S.C. § 2319(b)(1). The United States previously filed the Information
STIPULATION
Case4:11-cr-00642-SBA Document2 Filed09/08/11 Page2 of 2
1 TomorrowNow will enter guilty pleas to all twelve counts of the lnfonnation pursuant to
2 a Rule 11 (c)(1 )(C) plea agreement. The United States will lodge an under-seal copy of the
3 proposed plea agreement with the Court separately.
4 The United States and TomorrowNow will agree that the appropriate sentence is that set
6 The parties respectfully request that a change of plea and sentencing take place on
1 September 14, 20 II. The parties have agreed to waive a presentence investigation report, and do
8 not anticipate filing additional pleadings unless requested to do so by the Court. The United
9 States has notified Oracle about the proposed resolution and expects that a representative from
10 that company will be present at the hearing on September 14, 2011. The Oracle representative
MELINDA HAAG
United States Attorne
HABOERSCH
ey for TOMORROWNOW, INC.