Stipulation and [Proposed] Order to Schedule Change of Plea Hearing — United States v. Signorelli (Dkt. 8, N.D. Cal.)

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A stipulation and proposed order to schedule a change of plea hearing in United States v. Thomas Aaron Signorelli, No. CR 24-00516 JD, in the U.S. District Court for the Northern District of California, San Francisco Division, filed October 21, 2024 as Document 8. The parties state that on September 19, 2024 the government filed an information charging bank fraud under 18 U.S.C. § 1344, wire fraud and conspiracy, theft of government property under 18 U.S.C. § 641, falsification of records under § 1519 and conspiracy to launder money. The parties request a hearing at 10:30 a.m. on Monday, November 18, 2024; the attached proposed order, with a signature block for United States District Judge James Donato dated October 21, 2024, would schedule it for 10:30 a.m. on Monday, November 25, 2024.

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Case 3:24-cr-00516-JD Document 8 Filed 10/21/24 Page 1 of 2



 1   ISMAIL J. RAMSEY (CABN 189820)
     United States Attorney
 2
     MARTHA BOERSCH (CABN 126569)
 3   Chief, Criminal Division

 4   GARTH HIRE (CABN 187330)
     Assistant United States Attorney
 5
            450 Golden Gate Avenue, Box 36055
 6          San Francisco, California 94102-3495
            Telephone: (415) 436-6559
 7          FAX: (415) 436-7234
            Garth.Hire@usdoj.gov
 8
     Attorneys for United States of America
 9

10                                   UNITED STATES DISTRICT COURT

11                                NORTHERN DISTRICT OF CALIFORNIA

12                                       SAN FRANCISCO DIVISION

13   UNITED STATES OF AMERICA,                           No. CR 24-00516 JD

14                 Plaintiff,                            STIPULATION AND [PROPOSED] ORDER
                                                         TO SCHEDULE CHANGE OF PLEA
15                         v.                            HEARING

16   THOMAS AARON SIGNORELLI,

17                 Defendant.

18

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            Plaintiff United States of America, by and through its counsel of record, the United States
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     Attorney for the Northern District of California and Assistant United States Attorney Garth Hire, and
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     defendant Thomas Aaron Signorelli (defendant), by and through his counsel of record Thomas
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     Mazzucco and Philip Kearney, hereby stipulate as follows:
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            1.      On September 19, 2024, the government filed an Information charging defendant with
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     Bank Fraud in violation of 18 U.S.C. § 1344; Wire Fraud and Conspiracy to Commit Wire Fraud in
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     violation of 18 U.S.C. §§ 1343 & 1349; Theft of Government Property in violation of 18 U.S.C. § 641;
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     Destruction, Alteration, Falsification of Records in Federal Investigation in violation of 18 U.S.C. §
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     1519; and Conspiracy to Launder Money in violation of 18 U.S.C. § 1956(h).
28

                 Case 3:24-cr-00516-JD Document 8 Filed 10/21/24 Page 2 of 2



 1          2.      On September 20, 2024, defendant waived indictment, was arraigned on the

 2   information, entered a plea of not guilty, and was released on conditions of pretrial release.

 3          3.      The parties have reached a plea agreement and defendant is prepared to plead guilty.

 4   Based on the Court’s availability, the parties request that the matter be set for a change of plea hearing

 5   before this Court at 10:30 a.m. on Monday, November 18, 2024.

 6   IT IS SO STIPULATED.

 7    Dated: October 9, 2024                         ISMAIL J. RAMSEY
                                                     United States Attorney
 8
                                                        /S/ Garth Hire
 9                                                   GARTH HIRE
                                                     Assistant United States Attorney
10
                                                     Attorneys for Plaintiff
11                                                   UNITED STATES OF AMERICA

12
                   /S/ Thomas Mazzucco                                    10/9/2024
13   THOMAS MAZZUCCO                                             Date
     PHILIP KEARNEY
14   Attorney for Defendant
     Thomas Aaron Signorelli
15

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                                             [PROPOSED] ORDER
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            A change of plea hearing is hereby scheduled for 10:30 a.m. on Monday, November 25, 2024.
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            IT IS SO ORDERED.
19

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         October 21, 2024
21    DATE                                                   HONORABLE JAMES DONATO
                                                             UNITED STATES DISTRICT JUDGE
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