govinfo:USCOURTS-cand-4_26-cr-00288-0

STIP. TO SET CHANGE OF PLEA HEARING 
4:26-cr-288-HSG 1
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LORINDA I. LARYEA 
Chief, Fraud Section 
MATTHEW REILLY 
Acting Assistant Chief, Fraud Section 
AMANDA F. LINGWOOD 
Trial Attorney, Fraud Section 
United States Department of Justice 
Criminal Division, Fraud Section 
1400 New York Avenue N.W. 
Washington, D.C. 20005 
Matthew.Reilly2@usdoj.gov 
Amanda.Fretto.Lingwood@usdoj.gov 
Attorneys for United States of America 
UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF CALIFORNIA 
OAKLAND DIVISION 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
MINGRAN WANG, 
Defendant. 
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NO. 4:26-CR-288-HSG 
STIPULATION AND [PROPOSED] ORDER TO 
SET CHANGE OF PLEA HEARING 
The Fraud Section of the United States Department of Jus
tice’s Criminal Division (hereafter “the 
government”) and Defendant Wang have entered into a plea agreement and reached an agreed resolution 
in this matter, and the parties jointly request the Court set a change of plea hearing on June 24, 2026. 
On or about March 31, 2026, pursuant to the plea agreement, the defendant agreed to plead 
guilty to Count 1 of the captioned Information charging him with Use of Interstate Commerce for the 
Purpose of Securities Fraud in violation of 15 U.S.C. §§ 77q(a) and 77x. The parties lodged the plea 
agreement with the Court on or about June 12, 2026. Because the parties entered into the plea 
agreement on or about March 31, there is significant interest in seeing that the defendant’s case is 
resolved as expeditiously as possible. Undersigned government counsel is the assigned prosecutor and 

STIP. TO SET CHANGE OF PLEA HEARING 
4:26-cr-288-HSG 2
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is coordinating travel from Washington, D.C. to appear in person for the hearing. The parties conferred 
regarding availability for arraignment and the change of plea hearing and are available on June 24, 2026. 
This matter is currently set for initial appearance and arraignment on June 24, 2026, at 10:30 a.m. in 
Courtroom 4 before the Honorable Alex G. Tse. The parties therefore jointly stipulate and request that 
the Court set a change of plea hearing for June 24, 2026. 
Undersigned government counsel certifies that she has obtained approval from counsel for the 
defendant to file this stipulation and proposed order. 
IT IS SO STIPULATED. 
DATED: June 18, 2026 /s/ Amanda Lingwood 
AMANDA F. LINGWOOD 
Trial Attorn
ey, Fraud Section 
DATED: June 18, 2026 /s/ Amy Craig
AMY CRAIG 
Counsel 
for Defendant 
[PROPOSED] ORDER 
Based on the stipulation of the parties, and for good cause shown, the change of plea hearing is 
set for June 24, 2026, at ____ p.m. 
IT IS SO ORDERED. 
DATED: ___________________ _______________________ ____ 
HON. HAYWOOD S. GILLIAM, JR. 
U
n i t e d S t a t e s D i s t r i c t J u d g e 
2:00
June 18, 2026

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