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(602) 253-1048, z Teteph g = x = z < a ie = a a a 5 SC a = = Caer an eon —_— or THE Craig C. Gillespie, No. 013008 Dave Roscoe, No. 024529 3101 N. Central Ave., Suite 990 Phoenix, Arizona 85012 ‘Telephone: (602) 253-1010 Email: GLE@eraiggillespie.com Attorneys for Defendant IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF PINAL Case No. CR-201701197 MOTION TO CONTINUE DECEMBER Plaintiff, 2018 REVIEW HEARING AND SELF- SURRENDER DATE (UNOPPOSED) Expedited Ruling Requested STATE OF ARIZONA, v. CALEB BEERY, Assigned to the Honorable Stephen MeCarville Defendant, Review Hearing: 12/7/2018 at 1:30 p.m. Defendant Caleb Beery. by and through undersigned Counsel, hereby moves this Court for a 45-day continuance of the Review Hearing currently scheduled for Friday. December 7, 2018 at 1:30 p.m. Defense Counsel has confirmed Counsel for the State, David Ahl, has no objection to the requested continuance. Undersigned Counsel, Attorney Bruce Feder, Counsel for the Co-defendant, and Mr. Ahl participated in a conference call on the morning of December 5, 2018. The parties discussed different options to resolve the current impediment to the two defendants’ ability to participate in the county jail’s work release program. Following the conference call, undersigned Counsel spoke with Craig Cameron and Rodney States in the Civil Division of the Pinal County Attorney’s Office. Mr. States represents the jail and stated he would confer with the appropriate parties at the Pinal County Sheriff's Office and Mr. Ahl in an effort to help identify a possible solution to the work release impediment. The parties anticipate additional time will be needed beyond the December 7, 2018 date for self-surrender. “ONFORMED COPY FURNISHED % THE GILLESPIE LAW FIRM, P.C. v Further, a continuance is indispensable to the interests of justice. RESPECTFULLY SUBMITTED this 3% day of December, 2018. fespie, No. 013008 ie Law Firm, P.C. r Defendant ORIGINAL of the foregoing sent by FedEx this 5 day of December, 2018 to: Clerk of the Pinal County Superior Court 971 N. Jason Lopez Circle Florence AZ 85232 COPY of the foregoing emailed this same date to: The Honorable Stephen McCarville Pinal County Superior Court Email: rpadilla@courts.az.gov DCA David Ahi Pinal County Attorney's Office Email: David. Ahl@pinalcountyaz.gov Ann Bo Cer auwewn 10 ul 12 13 14 15. 16 7 18 19 20 21 22 23 24 25 26 27 28 STATE OF ARIZONA, Based on the foregoing and good cause appearing; IT IS HEREBY ORDERED: I8DEC-7 AM 9: 1h ox NM IN THE SUPERIOR COURT OF THE STATE OF ARIZONA. IN AND FOR THE COUNTY OF PINAL | Case No. CR-201701197 Plaintiff, | ORDER Continuing the December 7, 2018 Review Hearing in this matter to Gpsuary 247, 2019 at 10:00 «Ry pm.;and Decemao ¢ ore Date Pager dd ‘Toe of the Pinal County Superior Court