Joint Stipulation to Continue Government's Response to Defendant's Motion to Dismiss (ECF No. 20), and Defendant's Reply

(First Request)

NANCY J. KOPPE, Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between Nicholas A. Trutanich, United States Attorney, and Jared L. Grimmer, Assistant United States Attorney, counsel for the United States of America, Rene L. Valladares, Federal Public Defender, and Monique Kirtley, Assistant Federal Public Defender, counsel for Silvano Gonzalez-Castro, that the government's response to defendant's motion to dismiss (ECF No. 20) currently due on Friday, July 5, 2019, be vacated and continued to July 23, 2019, with defendant's corresponding reply due on July 30, 2019.

This Stipulation is entered into for the following reasons:

1. Government counsel continues to need additional time to properly respond to defendant's motion, to include researching the issues raised by the defendant.

2. Government counsel has requested a copy of records from the defendant's Immigration Court proceeding, and understands that it may be received within approximately three weeks of today's date. These records may be dispositive of the current motion.

3. Denial of this request for continuance could result in a miscarriage of justice.

4. This is the first request for continuance of the government response to defendant's motion to dismiss.

IT IS THEREFORE ORDERED that the government's response to defendant's motion to dismiss (ECF No. 20) currently due on Friday, July 5, 2019, be vacated and continued to July 23, 2019, with defendant's corresponding reply due on July 30, 2019.