Free Motion to Continue - District Court of Arizona - Arizona

Counsel has scheduled a videoteleconference with defendant for Wednesday, November 2, at 1:00. Defense counsel has conferred with AUSA Lisa Settel and she has no objection to this motion. In light of this request, defendant respectully requests an extension of the deadline for filing 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 2nd day of November, 2005 By /s/ Rena P. Glitsos

Copy of the foregoing was e-mailed/mailed/faxed/delivered this 2nd day of November, 2005 to: The Honorable David G. Campbell United States District Court Judge 401 W. Washington Phoenix, AZ 85003 Lisa Settel Assistant United States Attorney Two Renaissance Square 40 N. Central Phoenix, AZ 84004 By /s/ Rena P. Glitsos

Case 2:04-cr-00235-DGC

2 Document 35

Filed 11/02/2005

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Rena P. Glitsos, AZ Bar No. 013009
45 W. Jefferson, Suite 512 Phoenix, AZ 85003 (602) 528-0882 Attorney for Defendant IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ____________________________________ ) UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) v. ) ) FERNANDO PLAZA-TOLEDO, ) ) Defendant. ) ____________________________________) No. CR 04-235-1-PHX-DGC Motion to Continue Disposition (First Requested Continuance)

Defendant, through counsel, respectfully moves the Court to continue dispostion in the above-referenced matter for 30 days as defense counsel needs additional time to meet with defendant and go over the draft presentence/disposition report. Counsel had previously moved for a one week extension of time to file objections because she was unable to go over the presentence report with defendant due to technical problems with videoteleconferencing at CCA. At the time of that motion, counsel believed one week would be sufficient, however, her schedule did not permit her to meet with defendant as anticipated. This is the first sentencing date and defendant will not be prejudiced by the granting of this motion as it appears he is facing between 15 to 21 months on the new offense in addition to any time that may be given on his supervised release violation.

Case 2:04-cr-00235-DGC

Document 35

Filed 11/02/2005

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