USA v. Patterson

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STIPULATION AND ORDER - CONTINUANCE
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Bird & Van Dyke, Inc.
A Professional Law Corporation
David S. Van Dyke, CABN 154402
Mary Ann F. Bird, CABN 206770
2111 W. March Lane
Suite B300
Stockton, CA 95207
Telephone 	209.414.3266
Facsimile 	209.414.3268
Attorneys for Defendant MICHAEL LEE PATTERSON
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION
THE UNITED STATES OF AMERICA,
Plaintiff,
vs.
MICHAEL LEE PATTERSON,
Defendant.
Case No.: 4:24-CR-00225-HSG
STIPULATION AND ORDER TO
CONTINUE RESTITUTION HEARING (AS
MODIFIED)
STIPULATION
Plaintiff, United States of America, by and through its counsel of record, Assistant United States
Attorney Jonah Ross, and Defendant Michael Lee Patterson, by and through his counsel of
record, Mary Ann F. Bird, hereby stipulate as follows:
1. 	On December 17, 2025, this Honorable Court set a hearing for the determination of
victim restitution to be held on February 25, 2026.
2. 	Defense has been informed that the Government has continued to receive, as recently as
last week, restitution demands from the victims in this matter.
Case 4:24-cr-00225-HSG Document 70 Filed 02/11/26 Page 1 of 3

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STIPULATION AND ORDER - CONTINUANCE
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3. 	Because the restitution demands have not been finalized and discovered to Defense,
Defense needs additional time to receive, analyze and present information relevant to the
issue of total victim restitution to Defendant. The only method of communication
between Defendant and his counsel is through the United States Postal Service.
4. 	Defense has communicated the need for additional preparation time to the Government.
Having considered defense counsel’s request, the Government has no opposition to the
requested continuance for the restitution hearing.
5. 	Therefore, by this stipulation, Defense respectfully requests that this Court continue the
date for restitution hearing to May 27, 2026.
6. 	Defendant has been previously advised of his rights pursuant to Title 18 U.S.C. §§3663
and 3663A (Mandatory Victims Restitution Act), with waiver previously approved by the
Court and on file.
IT IS SO STIPULATED. 	Respectfully submitted,
Dated: February 10, 2026 	CRAIG H. MISSAKIAN
United States Attorney
___/s/ Jonah Ross___________
JONAH ROSS
Assistant United States Attorney
Dated: February 10, 2026 	___/s/ Mary Ann Bird_____________
MARY ANN F. BIRD
Attorney for MICHAEL LEE PATTERSON
///
///
Case 4:24-cr-00225-HSG Document 70 Filed 02/11/26 Page 2 of 3

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STIPULATION AND ORDER - CONTINUANCE
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FINDINGS AND ORDER
Based upon the facts set forth in the stipulation of the parties and for good cause shown,
the Court hereby continues the restitution hearing to May 27, 2026. The Court further finds that
the ends of justice are met by continuing the sentencing hearing to May 27, 2026, to allow all
victims in this matter to timely submit their claims for restitution pursuant to the Mandatory
Victims Restitution Act (“MVRA”). Therefore, and with the consent of the parties, IT IS
HEREBY ORDERED that the restitution hearing shall be continued to May 27, 2026 at 2:00
p.m. The Court confirms here that it will order restitution, as required by the MVRA, with only
the amount to be determined. See Dolan v. United States, 560 U.S. 605, 608 (2010).
IT IS SO ORDERED.
DATE: 	_______________________________________
HONORABLE HAYWOOD S. GILLIAM, JR.
UNITED STATES DISTRICT JUDGE
2/11/2026
Case 4:24-cr-00225-HSG Document 70 Filed 02/11/26 Page 3 of 3