NIALL E. LYNCH (State Bar No. 157959)	Filed 8/22/2006

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

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA	)	Case No. CR 06-0180 (PJH)

)

)	STIPULATION AND [PROPOSED]

v.	)	ORDER FOR EXPEDITED

)	SENTENCING UNDER L.R. 32-1(b)

)

)

SUN WOO LEE, YEONGHO KANG, and	)

YOUNG WOO LEE,	)

)	DATE: August 30, 2006
Defendants.	)	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	U.S. DEPARTMENT OF JUSTICE

BY: /s/ by BK	BY: /s/

Steven G. Madison	Niall E. Lynch, CA No. 157959

Quinn Emanuel	Nathanael M. Cousins, CA No. 177944

865 S. Figueroa Street	May Y. Lee, CA No. 209366

10th Floor	Brigid S. Biermann, CA No. 231705

Los Angeles, CA 90017	Charles P. Reichmann, CA No. 206699

Tel: (213) 443-3000	Trial Attorneys

Fax: (213)	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