Free Notice (Other) - District Court of California - California

Case 3:07-cr-03040-LAB

Document 12

Filed 11/29/2007

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VIKAS BAJAJ Law Office of Vikas Bajaj 225 Broadway, Suite 2200 San Diego, California 92101 Phone: (619) 525-7005 Facsimile: (619) 232-0001 Email: [email protected] California State Bar Number 216464 Attorney for Defendant: DAVID TRUNG NGUYEN UNITED STATES DISTRICT COURT

8 SOUTHERN DISTRICT OF CALIFORNIA 9 (HONORABLE LARRY A. BURNS) 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PLEASE TAKE NOTICE that on December 17, 2007, or as soon thereafter as counsel may be heard, DAVID TRUNG NGUYEN by and through his counsel, VIKAS BAJAJ, will ask the Court to enter an order granting the motions listed below. /// /// /// TO: KAREN P. HEWITT; UNITED STATES ATTORNEY AND PETER GREGORY KO, ASSISTANT UNITED STATES ATTORNEY: DAVID TRUNG NGUYEN Defendant v. Date: Time: December 17, 2007 2:00 p.m. UNITED STATES OF AMERICA Plaintiff NOTICE OF MOTION FOR DISCOVERY Case No.: 07CR03040-LAB

Case 3:07-cr-03040-LAB

Document 12

Filed 11/29/2007

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Date: November 28, 2007

MOTIONS The defendant, DAVID TRUNG NGUYEN, by and through his attorney, VIKAS BAJAJ, pursuant to 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. 2. Compel discovery and preserve evidence; Grant leave to file further motions.

These motions are based upon the instant motions and notice of motions, the attached statement of facts and memorandum of points and authorities, the attached exhibits , and any and all other materials that may come this Court's attention at the time of the hearing on these motions.

Respectfully submitted,

/s/ VIKAS BAJAJ Attorney for Defendant DAVID TRUNG NGUYEN