Free Motion to Continue Trial - District Court of Arizona - Arizona

In light of the above, Defendant respectfully requests an extension of the deadline for filing pretrial motions. The ends of justice served by the granting of this Motion to Continue outweigh the best interests of the public and the Defendant in a speedy trial. Excludable delay under 18 U.S.C. Section 3161(h) may occur as a result of this Motion or from any attendant orders.

RESPECTFULLY SUBMITTED this 27th day of February, 2006 By /s/ Rena P. Glitsos

I hereby certify that on February 27th , 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF system for filing and transmittal of Notice of Electronice Filing to the following CM/ECF registrants: Tom Simon, Esq. Assistant United States Attorney Two Renaissance Square 40 N. Central Phoenix, AZ 84004 /s/ Rena P. Glitsos

Case 2:00-cr-00269-SRB

2 Document 18

Filed 02/27/2006

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Rena P. Glitsos, AZ Bar No. 013009
Law Office of Rena P. Glitsos 45 W. Jefferson, Suite 512 Phoenix, AZ 85003 (602) 528-0882 Attorney for Defendant [email protected] IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ____________________________________ ) ) ) Plaintiff, ) ) v. ) ) ) BUCK SHORT, ) Defendant. ) ____________________________________) UNITED STATES OF AMERICA, No. CR 00-OO269-001-PHX-SRB

MOTION TO CONTINUE (Third Requested Continuance)

Defendant, through counsel, respectfully moves the Court to continue trial in the above-referenced matter for 60 days from the current date. The defense is requesting that a settlement conference be set in this matter for purposes of generating a report from the probation office. Mr. Short was on supervised release from the Bureau of Prisons at the time of the alleged escape. He was to stay at Behavioral Health Systems Southwest Community Corrections Center after having served a portion of the 3,392 days imposed on October 7, 1985, for a bank robbery charge out of Oregon. The sentence for that offense was imposed pursuant to the Sentencing Reform Act of 1984. Counsel believes that a probation report is necessary in order for her to adequately advise her client of all of the consequences of any plea in this matter.

Case 2:00-cr-00269-SRB

Document 18

Filed 02/27/2006

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