Opinion
2:19-cr-00295-GMN-NJK
04-04-2022
UNITED STATES OF AMERICA, Plaintiff, v. MARIO CASTRO, JOSE SALUD CASTRO, SALVADOR CASTRO, MIGUEL CASTRO, AND JOSE LUIS MENDEZ, Defendant.
TANASI LAW OFFICES RICHARD E. TANASI, ESQ. Nevada State Bar No. 9699 Attorney for Mario Castro CHRISTOPHER CHIOU Acting United States Attorney MINA CHANG Assistant United States Attorney Office of the United States Attorney GUSTAV W. EYLER Director TIMOTHY FINLEY DANIEL ZYTNICK Trial Attorneys U.S. Department of Justice Attorneys for the United States
TANASI LAW OFFICES
RICHARD E. TANASI, ESQ.
Nevada State Bar No. 9699
Attorney for Mario Castro
CHRISTOPHER CHIOU
Acting United States Attorney
MINA CHANG
Assistant United States Attorney
Office of the United States Attorney
GUSTAV W. EYLER Director
TIMOTHY FINLEY
DANIEL ZYTNICK
Trial Attorneys U.S. Department of Justice
Attorneys for the United States
STIPULATION AND ORDER TO CONTINUE DEADLINE FOR DEFENDANT MARIO CASTRO TO REPLY TO GOVERNMENT RESPONSE ECF 314.
(FIRST REQUEST)
Gloria M. Navarro, District Judge
IT IS HEREBY STIPULATED AND AGREED, by and between the United States of America, by and through Timothy Finley, U.S. Department of Justice Trial Attorney, and MARIO CASTRO, by and through his attorney, Richard E. Tanasi, Esq., that Defendant Castro's deadline to Reply to the Government's Response to Mario Castro's Motion to Preclude 404(b) Evidence [ECF Nos. 289, 314], previously set for March 29, 2022 be vacated and continued to July 1, 2022.
This Stipulation is entered into for the following reasons:
1. On March 30, 2022, the Honorable District Court Judge Navarro continued the trial date and other pleading deadlines related to Defendant Castro to July 1, 2022. [ECF No. 325.]
2. Defendant Castro requests the July 1, 2022 deadline for all reasons outlined in his Motion to Continue. [ECF No. 316.] The government does not object to this request given the new trial Order in this case.
3. The additional time requested herein is not sought for purposes of delay.
4. Additionally, denial of this request for continuance could result in a miscarriage of justice.
WHEREFORE, the parties respectfully request that this Honorable Court accept the Stipulation and enter an Order as set forth below, continuing Defendant Castro's deadline to Reply to the Government's Response to Mario Castro's Motion to Preclude 404(b) Evidence [ECF Nos. 289, 314.], previously set for March 29, 2022 be vacated and continued to July 1, 2022.
IT IS SO ORDERED.