Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

1 JON M. SANDS Federal Public Defender 2 850 West Adams, Suite 201 Phoenix, Arizona 85007-2730 3 Telephone: (602) 382-2755 4 DOUGLAS A. PASSON, #017423 5 [email protected] Asst. Federal Public Defender 6 Attorney for Defendant 7 8 9 10 11 12 13 14 15 16 17 18 19 20 vs. Scott Segal, Defendant. Defendant, Scott Segal, through counsel, moves the Court to extend his self-surrender date for ninety (90) days from the current date of November 14, 2005. The first reason for this motion is that Mr. Segal is currently set for sentencing in the District of Massachusetts in the related criminal cause number on November 10, 2005. It is likely that Mr. Segal will receive a self-surrender date in that matter Plaintiff, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA United States of America, No. CR-04-378-PHX-SRB MOTION TO EXTEND SELF-SURRENDER DATE

th 21 beyond the date of the November 14 deadline in this case. It is also possible that the 22 Bureau of Prisons will require additional time to complete Mr. Segal's designation

23 given the additional sentence imposed in Massachusetts. In addition, Mr. Segal is 24 still in the process of selling the family home in Massachusetts and relocating his 25 mother to the Phoenix area. He requires additional time to make those arrangements. 26 Defense counsel has contacted Assistant United States Attorney, Fred 27 Battista, concerning this motion. Mr. Battista indicates that the government has no 28 objection to the requested extension.

Case 2:04-cr-00378-SRB

Document 148

Filed 10/27/2005

Page 1 of 2

1

WHEREFORE, Mr. Segal respectfully requests this Court to extend his

2 self-surrender date of November 14, 2005, by ninety (90) days. 3 It is expected that excludable delay under Title 18 U.S.C. Section 4 3161(h)(1)(F) may occur as a result of this motion or from an order based thereon. 5 6 7 8 9 10 JON M. SANDS Federal Public Defender s/ Douglas A. Passon DOUGLAS A. PASSON Asst. Federal Public Defender Respectfully submitted: October 27, 2005.

11 I hereby certify that on October 27, 2005, I electronically transmitted the attached 12 document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: 13 FRED BATTISTA 14 Assistant U.S. Attorney Two Renaissance Square 15 40 N. Central, Suite 1200 Phoenix, Arizona 85004-4408 16 Copy mailed to: 17 CRAIG HARAGA 18 U.S. Probation Office Courthouse 19 Sandra Day O'Connor U.S. Suite 160 401 W. Washington Street, 20 Phoenix, Arizona 85003 21 LOUIS ALOISE, ESQ. One Exchange Place 22 Worcester, MA 01608 23 SCOTT SEGAL Defendant 24 25 27 28 2 s/ S. Bereolos S. Bereolos 26

Case 2:04-cr-00378-SRB

Document 148

Filed 10/27/2005

Page 2 of 2