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Notice of Motion and Motion to Compel Discovery/Preserve Evidence — United States v. Bhakta (S.D. Cal.), Dkt.

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A Notice of Motion and Motion to Compel Discovery/Preserve Evidence, filed 01/02/22 as Document 13 in United States v. Denny Bhakta, Case 3:21-cr-03352, Southern District of California. The notice is addressed to Randy S. Grossman, Acting United States Attorney, and Andrew Galvin, Assistant United States Attorney. It states that on January 21, 2022, at 1:30 p.m., or as soon thereafter as counsel may be heard, Defendant Denny Bhakta will present the Motion to Compel Discovery and Preserve Evidence. The signature line reads /s/ Sandra Resnick, attorney for Defendant Denny Bhakta, dated January 2, 2022.

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“Notice of Motion and Motion to Compel Discovery/Preserve Evidence — United States v. Bhakta (S.D. Cal.), Dkt.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-cal-no-3-21-cr-03352-dkt-13-s-d-cal-1bea56669c/, SHA-256 96e6f94dc31329f88ea2e317ac67e289422ba44941195db36de986c531d8e730.

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Case 3:21-cr-03352-JLS Document 13 Filed 01/02/22 PagelD.60 Page 1 of 2

SANDRA RESNICK
California State Bar # 89901
270 East Douglas Avenue
El Cajon, CA 92020
Office: (619) 401- 4067
Fax: (619) 442-7439

Attorney for Defendant
Denny Bhakta

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
(Hon. JANIS L SAMMAR TINO)

UNITED STATES OF AMERICA, CASE NO. 21 CR 3352-JLS
Plaintiff, Date: January 21, 2022
Time: 1:30 p.m.
V.
NOTICE OF MOTION AND
DENNY BHAKTA MOTION TO COMPEL
DISCOVERY/PRESERVE
EVIDENCE
Defendant.

TO: RANDY S. GROSSMAN, ACTING UNITED STATES ATTORNEY;
ANDREW GALVIN, ASSISTANT UNITED STATES ATTORNEY,

PLEASE TAKE NOTICE that on January 21, 2022 at 1.300 p.m. or as
soon thereafter as counsel may be heard, the Defendant, DENNY BHAKTA will

present the following Motion to Compel Discovery and Preserve Evidence.

Said Motion will be based upon this Notice of Motion, the Motions attached
hereto, the Statement of Facts and Points of Authorities filed herewith, as well as

any and all other evidence presented at the time of the hearing of said Motions.
Case 3:21-cr-03352-JLS Document 13 Filed 01/02/22 PagelD.61

Dated: January 2, 2022 Respectfully submitted,

/s/ Sandra Resnick
SANDRA RESNICK
Attorney for Defendant
Denny Bhakta

Page 2 of 2

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