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Notice of Motion and Motion to Grant the Defense Leave to File Further Motions — United States v. Bhakta

Summary

This is a Notice of Motion and Motion to Grant the Defense Leave to File Further Motions, filed by Sandra Resnick, attorney for defendant Denny Bhakta. The notice is addressed to Randy S. Grossman, Acting United States Attorney, and Andrew Galvin, Assistant United States Attorney, and gives a hearing date of January 21, 2022, at 1:30 p.m. The motion states that Bhakta and defense counsel are continuing to receive discovery, and that the discovery may require the retention of a defense expert and may result in additional motions. It is signed /S/ Sandra Resnick, dated January 2, 2022.

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“Notice of Motion and Motion to Grant the Defense Leave to File Further Motions — United States v. Bhakta.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-cal-no-3-21-cr-03352-dkt-14-s-d-cal-819b99ed87/, SHA-256 29b391dde1397070a6a4c027bf18b352b6129784a2f27551bac9fb7718e09bda.

Full text

       Case 3:21-cr-03352-JLS Document 14 Filed 01/02/22 PageID.72 Page 1 of 2



 1 SANDRA RESNICK
   Attorney at Law
 2 California State Bar No. 89901
   270 East Douglas Avenue
 3 El Cajon, California 92020
   Telephone No. (619) 401- 4067
 4
 5   Attorney for Defendant
     DENNY BHAKTA
 6
 7
 8
                         UNITED STATES DISTRICT COURT
 9
                      SOUTHERN DISTRICT OF CALIFORNIA
10
                      (HONORABLE JANIS L. SAMMARTINO)
11
12
13   UNITED STATES OF AMERICA,    )               CASE NO. 21 CR 3352-JLS
                                  )
14            Plaintiff,          )               Date: January 21, 2022
                                  )               Time: 1:30 p.m.
15 v.                             )
                                  )               NOTICE OF MOTION AND
16                                )               MOTION TO GRANT THE
    DENNY BHAKTA         ,        )               DEFENSE LEAVE TO FILE
17                                 )               FURTHER MOTIONS
                                  )
18           Defendant.           )
                                  )
19 _______________________________)
20
21 TO: RANDY S. GROSSMAN, ACTING UNITED STATES ATTORNEY, and
22 ANDREW GALVIN, ASSISTANT UNITED STATES ATTORNEY:
23        PLEASE TAKE NOTICE that on January 21, 2022 at 1:30 p.m., or as soon
24 thereafter as counsel may be heard, Denny Bhakta will move the court to grant
25 leave to file additional motions based on any further discovery which may be
26 received subsequent to the filing of the initial Motion For Discovery.
27
28                                          -1-
   Case 3:21-cr-03352-JLS Document 14 Filed 01/02/22 PageID.73 Page 2 of 2



                                       MOTION
      The defendant, DENNY BHAKTA, by and through his attorney, Sandra
Resnick, pursuant to the Fifth, and Sixth Amendment to the United States
Constitution, the Federal Rules of Criminal Procedure 12(b)(1), 12(b)(3), and
12(b)4), and all other applicable statutes, case law and local rules, hereby moves
this Court for an order to:
             (1) Grant the defense leave to file further motions.
                                       I
 THE COURT SHOULD GRANT LEAVE TO FILE FURTHER MOTIONS.
      Mr. Bhakta requests leave to file further motions in the event additional
discovery gives rise to the need for further pre-trial proceedings. Mr. Bhakta and
defense counsel are continuing to receive discovery. This discovery may require
the retention of a defense expert to review and analyze data which may result in the
filing of additional motions.


                                   CONCLUSION
      For the foregoing reasons, Mr. Bhakta respectfully requests that the Court
grant leave to file further motions.          .

                                              Respectfully submitted,
Dated: January 2, 2022
                                              /S/ Sandra Resnick
                                              SANDRA RESNICK
                                              Attorney for Defendant
                                              Denny Bhakta

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