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United States v. Reyes-Castillo

United States District Court, D. Nevada

January 6, 2020

United States of America, Plaintiff,
v.
Jose Luis Reynaldo Reyes-Castillo, et al. Defendants.

          Richard A. Wright Wright Marsh & Levy John Balazs Attorney at Law 916 2nd Street, Suite F Sacramento, CA 95814 Attorneys for defendant Jose Luis Reynaldo Reyes-Castillo

          MOTION TO AMEND COMPLEX CASE SCHEDULING ORDER

          CAM FERENBACH DATE UNITED STATES MAGISTRATE JUDGE

         Defendants JOSE LUIS REYNALDO REYES-CASTILLO, MIGUEL TORRES-ESCOBAR, and DAVID ARTURO PEREZ-MANCHAME, through their respective attorneys, hereby move the Court to amend the complex case scheduling order entered in this case on June 7, 2019 (ECF No. 28) as set forth below. Counsel for the government do not oppose this motion. Given the complexity of the evidence, volume of discovery, and death penalty protocol process (for all three charged defendants), it is unreasonable to expect each defendant could adequately prepare for trial within the timeframe mandated by the Speedy Trial Act and the initial complex case scheduling order .

         I.COMPLEXITY AND VOLUME OF THE CASE

         A. The Charges, Potential Penalties, and Case Status

         1. On April 30, 2019, a federal grand jury seated in Las Vegas, Nevada returned a three-count Indictment charging three defendants - JOSE LUIS REYN-ALDO REYES-CASTILLO, a.k.a. “Molesto, ” MIGUEL TORRES-ESCOBAR, a.k.a. “Chamilo, ” and DAVID ARTURO PEREZ-MANCHAME, a.k.a. “Walter Melendez, ” a.k.a. “Herbi” -- with offenses related to the January 21, 2018 murder of Arquimidez Sandoval-Martinez. (ECF No. 1). More specifically, all three defendants are charged with Murder in Aid of Racketeering (VICAR Murder), in violation of Title 18, United States Code, Sections 1959(a)(1) and 2 (Count One); Using, Carrying, and Discharging a Firearm During and In Relation to a Crime of Violence, in violation of Title 18, United States Code, Sections 924(c) (Count Two); and Causing Death Through the Use of A Firearm, in violation of Title 18, United States Code, Sections 924(j) and 2 (Count Three).

         2. Counts One and Three are both death penalty eligible offenses. Count Two carries a mandatory minimum penalty of 10 years' imprisonment and a statutory maximum penalty of life imprisonment.

         3. The Indictment alleges that the defendants were members and associates of the criminal street gang Mara Salvatrucha, commonly known as MS-13, and the Parkview clique in Las Vegas, Nevada, specifically. The Indictment further alleges that MS-13, including its leaders, members, and associates, constituted an enterprise which engaged in racketeering activity consisting of multiple acts involving murder, kidnapping, and robbery, among other offenses.

         4. The discovery in this case will be voluminous. It includes, but is not limited to, thousands of pages of documents, including the complete “murder book”, investigative reports from both federal and state agencies, court documents, photographs, medical examiner reports, summaries and/or transcripts of multi-hour interviews with various individuals (several of which involve Spanish speakers and are in the process of being translated), toll records, forensic reports and related data, social media records, and other such materials; multiple audio and video recordings; and items of physical evidence, including clothing, knives, firearms, and other such items.

         5. On September 26, 2019, the Court granted the parties motion for a protective order governing discovery. (ECF No. 41).

         6. On or about October 15, 2019, the Government produced initial discovery involving its “murder book” for the Sandoval-Martinez murder as set forth in paragraph 4, above. The defendants have begun reviewing this discovery and will require substantial additional time in order to thoroughly review the discovery, conduct any necessary follow-up investigation, apprise their clients of the nature of the evidence against them, and research, prepare, and file any necessary pretrial motions that defense counsel deem necessary given the evidence and posture of the case. Counsel will also need to review discovery in order to make an informed decision as to whether to seek a plea agreement.

         7. A number of counsel in this case, including both counsel for defendant Perez-Manchame and learned counsel for defendant Torres-Escobar, have also been representing parties in a pending trial in United States v. Palafox, No. 2:16-CR-0265-GMN. That trial started on July 29, 2019 and is not expected to conclude until later this month.

         8. Moreover, all three defendants are charged with death penalty eligible offenses. Whether the government decides to seek death or seek approval not to seek death, such requires compliance with death penalty protocol processes which will be time-consuming and will require participation of counsel for each defendant with regard to presenting mitigating information. Defense counsel will need sufficient time to accumulate mitigation information to present to the United States Attorney and the Attorney General of the United States.

         B. Proposed Complex Case Schedule

         i. The Initial ...


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