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NIALL E. LYNCH (State Bar No. 157959)
NATHANAEL M. COUSINS (State Bar No. 177944)
MAY Y. LEE (State Bar No. 209366)
BRIGID S. BIERMANN (State Bar No. 231705)
CHARLES P. REICHMANN (State bar No. 206699)
Antitrust Division
U.S. Department of Justice
450 Golden Gate Avenue
Box 36046, Room 10-0101
San Francisco, CA 94102
Telephone: (415) 436-6660

Attorneys for the United States

Filed 8/22/2006


UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION



UNITED STATES OF AMERICA    

                  v.

SUN WOO LEE, YEONGHO KANG, and
YOUNG WOO LEE,

                  Defendants.


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Case No. CR 06-0180 (PJH)

STIPULATION AND [PROPOSED]
ORDER FOR EXPEDITED
SENTENCING UNDER L.R. 32-1(b)

DATE: August 30, 2006
TIME: 2:30 p.m.
COURT: Hon. Phyllis J. Hamilton

On March 22, 2006, the United States filed an Information charging Young Woo Lee with participating in a conspiracy in the United States and elsewhere to suppress and eliminate competition by fixing the prices of DRAM to be sold to certain OEM customers during various periods of time from June 1, 2001, until June 15, 2002, in violation of the Sherman Antitrust Act, 15 U.S.C. § 1. Young Woo Lee (the "Defendant") is scheduled for a change of plea and possible sentencing on August 30, 2006. Defendant has agreed to waive Indictment and plead guilty under Fed. R. Crim. P. 11(c)(1)(C). The United States and Defendant will file the Plea Agreement and a Joint Sentencing Memorandum describing the material terms of the Plea Agreement and the agreed upon sentencing recommendation.

IT IS HEREBY STIPULATED AND AGREED as follows:

The United States and Defendant request that the Court sentence Defendant on an expedited basis pursuant to Crim. L.R. 32-1(b), on August 30, 2006. The United States and Defendant respectfully submit that the Joint Sentencing Memorandum and the Plea Agreement provide sufficient information for the Court to impose a sentence on August 30, 2006, the same date as the change of plea hearing, without a presentence report.

DATED: August 22, 2006

Respectfully submitted,

YOUNG WOO LEE

BY:_____________/s/ by BK____________
Steven G. Madison
Quinn Emanuel
865 S. Figueroa Street
10th Floor
Los Angeles, CA 90017
Tel: (213) 443-3000
Fax: (213)

U.S. DEPARTMENT OF JUSTICE

BY:_______________/s/________________
Niall E. Lynch, CA No. 157959
Nathanael M. Cousins, CA No. 177944
May Y. Lee, CA No. 209366
Brigid S. Biermann, CA No. 231705
Charles P. Reichmann, CA No. 206699
Trial Attorneys
U.S. Department of Justice
Antitrust Division
450 Golden Gate Avenue
Box 36046, Room 10-0101
San Francisco, CA 94102
Tel: (415) 436-6660
Fax: (415) 436-6687