Can a motion for a new trial be denied because the clerk failed to mail notice of an order denying it to the parties?

This court faced a similar situation in United States v. Buzard, 884 F.2d 475 (9th Cir.1989), cert. denied, 495 U.S. 906, 110 S.Ct. 1927, 109 L.Ed.2d 291 (1990). In that case, the district court filed an order on July 26, 1988, which was docketed on July 28, 1988, denying the defendant's motion for a new trial. The clerk failed to mail notice of the order to the parties. On September 23, 1988, counsel for the defendant notified the district judge that he believed the motion for new trial to have not been ruled upon as of that date. The district judge then declared that the order denying the defendant's motion for a new trial would "be deemed to have been filed" in September instead of July. Id. at 475.