Free Motion for Miscellaneous Relief - District Court of California - California

Case 3:08-cr-02643-JAH

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Filed 08/15/2008

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KAREN P. HEWITT United States Attorney JOSEPH K. WHEATLEY Special Assistant United States Attorney Trial Attorney, U.S. Department of Justice 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-6882 c/o Stephanie Delgadillo Email [email protected] Attorneys for Plaintiff United States of America UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. RODERICK VANG THOR, Defendant. ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08-CR-2643-IEG

UNOPPOSED MOTION REGARDING NOTICE OF RELATED CASE

The UNITED STATES hereby files this Unopposed Motion Regarding Notice of Related Case. Russell Babcock, Attorney for RODERICK VANG THOR, has no objection to the Motion. The government respectfully moves the Court to take notice that the above-entitled case is related to United States v. Phuong Quoc Truong, et al., Criminal Case No. 07-CR-1312-JAH. Pursuant to a signed Plea Agreement, both parties agree that this case is related to Criminal Case No. 07-CR-1312-JAH, because the defendant's case is a part of the conspiracy alleged in Criminal Case No. 07-CR-1312-JAH. Both parties further agree that the government would file a Notice of Related Case, which is being filed contemporaneously. DATED: August 15, 2008. Respectfully submitted, KAREN P. HEWITT United States Attorney s/ Joseph K. Wheatley JOSEPH K. WHEATLEY Special Assistant U.S. Attorney Trial Attorney, U.S. Department of Justice

Case 3:08-cr-02643-JAH

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Filed 08/15/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1. 19 20 21 22 23 I declare under penalty of perjury that the foregoing is true and correct. 24 Executed on August 15, 2008. 25 26 27 28 s/ Joseph K. Wheatley JOSEPH K. WHEATLEY I hereby certify that I have caused to be mailed the foregoing, by the United States Postal Service, to the following non-ECF participants on this case: 1. None Russell Babcock; 1400 6th Avenue, Suite 210b; San Diego, CA 92101 I have caused service of UNOPPOSED MOTION REGARDING NOTICE OF RELATED CASE on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. IT IS HEREBY CERTIFIED THAT: I, JOSEPH K. WHEATLEY, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. v. RODERICK VANG THOR, Defendant. UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08-CR-2643-IEG UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

CERTIFICATE OF SERVICE

the last known address, at which place there is delivery service of mail from the United States Postal Service.