Unopposed Motion to Continue Motions Deadline for Two Weeks by Don v. Cisternino — USA v. Cisternino (Dkt. 23, M.D. Fla.)

Record facts

U.S. District Court for the Middle District of Florida · No. 6:21-cr-00016-AGM-DCI · Doc. 23 · 2022-06-10 · Docket on CourtListener

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United States District Court 
Middle District of Florida 
Orlando Division 
 
 
United States of America, 
 
Plaintiff, 
 
v. 
 
 
 
 
 
     Case No: 6:21-cr-16-WWB-DCI 
 
Don V. Cisternino, 
 
  
Defendant. 
                                 /   
 
Unopposed Motion To Continue The Motions Deadline For Two Weeks 
 
 
The government does not oppose a two-week continuance of the motions 
deadline, which is today, June 10, 2022.  The case is set for the August term with 
a status conference set on July 12, 2022.  Doc. 22.  The time is needed to review 
the discovery for any potential legal issues.   
 
Counsel would like the additional time due to scheduling issues.  Counsel 
was out of the district for a training conference from May 9 to May 15, 2022, and 
then was on leave May 27 to June 1, 2022.  During this time Counsel was also 
preparing for a major sentencing in United States v. Brown, 6:21-cr-115-WWB-
DCI.   
The discovery is somewhat voluminous and the case somewhat complex.  
Mr. Cisternino is accused of defrauding the Payroll Protection Program, which 
was enacted as part of a COVID relief package, of about $7.2 million.  He is also 
accused of several instances of aggravated identity theft.  Thus, Mr. faces 
Case 6:21-cr-00016-AGM-DCI     Document 23     Filed 06/10/22     Page 1 of 2 PageID 49

serious consequences.  The Court, of course, has the authority to extend the 
time of its own deadlines.  See, Rule 45(b)(1), Fed.R.Crim.Proc. 
 
 
 
 
Respectfully submitted,  
A. Fitzgerald Hall, Esq. 
Federal Defender, MDFL 
 
/s/ Michael S. Ryan                      
Michael S. Ryan, Esq. 
Assistant Federal Defender 
Arizona Bar No. 0018139 
201 S. Orange Avenue, Suite 300 
Orlando, FL 32801 
Telephone: 407-648-6338 
Fax: 407-648-6095 
E-Mail: michael_ryan@fd.org 
 
 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that undersigned electronically filed the foregoing with 
the Clerk of Court (CM/ECF) by using the CM/ECF system which will send a notice 
of electronic filing to Chauncey Bratt, Assistant United States Attorney, this 10th  
day of June 2022. 
 
/s/ Michael S. Ryan                       
 
 
 
 
 
 
Attorney for Defendant 
Case 6:21-cr-00016-AGM-DCI     Document 23     Filed 06/10/22     Page 2 of 2 PageID 50

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