Free Motion to Continue - District Court of Arizona - Arizona

Rena P. Glitsos
45 W. Jefferson, Suite 512 Phoenix, AZ 85003 (602) 528-0882 AZ State Bar No. 013009 Attorney for Defendant

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA

________________________________________ ) ) UNITED STATES OF AMERICA ) ) Plaintiff, ) ) v. ) ) CHARLES BUCK SHORT ) ) Defendant. ) ) _______________________________________ )

No. CR 00-00269-001-PHX-SRB MOTION TO CONTINUE AND EXTEND DEADLINE (First Requested Continuance)

Defendant, through counsel, respectfully moves the Court to continue trial in the abovereferenced case. 1. Defense counsel is currently engaged in ongoing discovery and investigation in

the above matter, and is requesting a sixty (60) day extension of time within which to complete discovery. 2. Defense counsel has contact attorney for the Government, Tom Simon, who has

no objection to the court granting an extension of time. 3. The ends of justice served by the granting of this Motion to Continue outweigh

Case 2:00-cr-00269-SRB

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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. 4. In light of the request for a continuance defendant respectfully moves the Court to

extend the deadline for filing pre-trial motions accordingly. 5. Therefore, it is respectfully requested that the Court grant the defendants Motion

to Continue for 60 days within which to complete discovery. Respectfully submitted this 17th day of October, 2005 at Phoenix, Arizona.

By/s/ Rena P. Glitsos

Copy of the foregoing was mailed/faxed/delivered this 17th day of October, 2005 to: The Honorable Susan R. Bolton United States District Court Judge 401 W. Washington Phoenix, AZ 85003 Assistant United States Attorney Thomas Simon Two Renaissance Square 40 N. Central Phoenix, AZ 85004

By /s/ Rena P. Glitsos

Case 2:00-cr-00269-SRB

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Case 2:00-cr-00269-SRB

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Filed 10/17/2005

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