“escape” offense for purposes of sentencing. See Burtlow, 299 N.W.2d at 668 (“Even though the word ‘escape’ does not appear in subsection three, the crime is plainly an escape offense within the meaning of [the consecutive sentence statute].”). The Ninth Circuit Court of Appeals found no basis upon which to distinguish escape and failure-to-appear offenses in the context of a continuing-offense analysis: [A] defendant who fails to appear for sentencing presents a threat to society analogous to that posed by an escaped prisoner. Both are convicted criminals obligated to serve sentences or facing sentencing. In addition, the failure of a defendant to appear for sentencing poses a threat to the integrity and authority of the court. United States v. Gray, 876 F.2d 1411, 1419 (9th Cir.1989) (<HOLDING>), cert. denied, 495 U.S. 930, 110 S.Ct. 2168,
holding that failure to appear for sentencing is a continuing offense because a convicted criminal has a continuing obligation to face sentencing and presents an ongoing threat to the integrity and authority of the court so long as he has not appeared holding that the defendants oral promise to appear was insufficient to amount to a required appearance within the meaning of the failure to appear statute holding that dismissal for failure to appear at a deposition is on the merits holding that failure to appear when released on bond was a continuing offense holding that failure to appear is also a continuing offense