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Joint Motion to Continue the Motion Hearing and Trial Setting to July 15, 2022 — United States v. Bhakta

Summary

Joint Motion to Continue the Motion Hearing and Trial Setting to July 15, 2022, filed May 3, 2022, in United States of America v. Denny Bhakta, Case No. 3:21-CR-3352-JLS. It states that a grand jury returned an indictment on December 1, 2021, and that the United States has produced over 1,000 pages of discovery. It also states that the United States recently produced records related to Paycheck Protection Program (PPP) loans and needs time to analyze the approximately 17 PPP loan applications Defendant submitted. The parties ask that time be excluded under the Speedy Trial Act. It is signed /s/ by Eric R. Olah and Sandra Resnick.

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“Joint Motion to Continue the Motion Hearing and Trial Setting to July 15, 2022 — United States v. Bhakta.” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-s-d-cal-no-3-21-cr-03352-dkt-30-s-d-cal-220ecf3b85/, SHA-256 f8fbf43ada1ee7fb013d4218128f5b7a861e092f7852a7eae5eb7438ce7e1fb8.

Full text

         Case 3:21-cr-03352-JLS Document 30 Filed 05/03/22 PageID.100 Page 1 of 2




 1 RANDY S. GROSSMAN
 2 United States Attorney
   ERIC R. OLAH
 3 Assistant U.S. Attorney
 4 California Bar No. 295513
   Office of the U.S. Attorney
 5 880 Front Street, Room 6293
 6 San Diego, CA 92101
   Tel: (619) 546-7540
 7 Email: eric.olah@usdoj.gov
 8
     Attorneys for the United States
 9
10                          UNITED STATES DISTRICT COURT

11                       SOUTHERN DISTRICT OF CALIFORNIA
12    UNITED STATES OF AMERICA,                 Case Nos.: 3:21-CR-3352-JLS
13                 Plaintiff,
                                                JOINT MOTION TO CONTINUE
14           v.                                 THE MOTION HEARING AND
                                                TRIAL SETTING TO JULY 15, 2022
15
      DENNY BHAKTA,
16
                   Defendant.                   The Honorable Janis L. Sammartino
17
18          The United States of America, by and through its counsel, Randy S. Grossman,
19 United States Attorney, and Eric R. Olah, Assistant United States Attorney, and Defendant
20 Denny Bhakta, through counsel Sandra Resnick, hereby jointly move this Court for an
21 order continuing the Motion Hearing and Trial Setting, currently set for May 13, 2022, to
22 July 15, 2022 at 1:30 p.m., and excluding time under the Speedy Trial Act. The parties’
23 joint Motion is based on the following:
24          1.    On December 1, 2021, a grand jury returned an indictment charging
25 Defendant with securities fraud, money laundering, and criminal forfeiture. ECF No. 1.
26          2.    On December 14, 2021, Defendant made his initial appearance in the case and
27 the Court appointed current counsel to represent Defendant. ECF No. 4.
28 / /
      Case 3:21-cr-03352-JLS Document 30 Filed 05/03/22 PageID.101 Page 2 of 2




 1        3.     The United States has since produced over 1,000 pages of discovery,
 2 including law enforcement reports, bank records, and emails.
 3        4.     The United States recently produced records related to Paycheck Protection
 4 Program (PPP) loans that Defendant applied for and received, and it anticipates producing
 5 more such records shortly. The requested continuance will allow defense counsel to review
 6 that discovery and discuss it with Defendant. The continuance will also the United States
 7 to more thoroughly analyze the approximately 17 PPP loan applications that Defendant
 8 submitted and determine whether to seek charges based on those submissions.
 9        5.     Defendant filed a discovery motion on January 2, 2022 (ECF No. 13) that
10 remains pending.
11        Based on the above, it would be unreasonable to expect adequate preparation for
12 pretrial proceedings and trial to be completed within the otherwise applicable time limits.
13 Therefore, the parties agree that the time from May 13, 2022 through July 15, 2022, shall
14 be excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A), on the grounds that
15 the ends of justice served by such a continuance outweigh the best interest of the public
16 and the defendant in a speedy trial.
17        In the alternative, the Court should that time from May 13, 2022 through July 15,
18 2022, shall be excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(1)(D), based on
19 the pending discovery motion (ECF No. 13) and the need for a continuance to adequately
20 address the issues raised in the motion.
21 DATED: May 3, 2022                                  Respectfully submitted,
                                                       RANDY S. GROSSMAN
22
                                                       United States Attorney
23
                                                       /s/ Eric R. Olah
24
                                                       ERIC R. OLAH
25                                                     Assistant United States Attorney
26 DATED: May 3, 2022                                  /s/ Sandra Resnick
27                                                     SANDRA RESNICK
                                                       Counsel for Defendant
28                                                     (as authorized via email on 05/03/22)

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