Boehlke State of Minnesota REC����� District Court, 2"d Judicial District
County of Ramsey �0� � � ��'� Case No. (OaG �C:b � �,���0
CITY CLER� Case Type: Criminal
STATE OF MINNESOTA
� Notice of Motion and Motion
To Reopen Case
�YL� �s�� �����..�
Name of Defendant(s)/Respondent(s)
TO: Plaintiff
To be completed by Hearing Officer:
PLEASE TAKE NOTICE THAT on at o'clock_.m
(Date of Hearing) (tfine of hearing)
Before , Judge of the District Court, in Room located at
Name of]udge or Referee
❑ 15 West Kellogg Blvd in the City Hall / Courthouse in the City of St. Paul, State of Minnesota, 55102
❑ 2050 White Bear Ave./ Courthouse in the City of Maplewood, State of Minnesota, 55109
I will ask the Court for an Order as follows
MOTION
I am asking the Court to grant a motion to reopen this case and for a withdrawal of guilty plea for the
fO��OWll1g CeclSOf1S: (tell the Court why you are asking for your requests):
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v�o c� c� �rn.� �c'.QLo�
3. Verification and Acknowledgements:
a. I have read this document. To the best of my knowledge, information and belief the information
contained in this document is well grounded in fact and is warranted by existing law.
b. I have not been determined by any court in Minnesota or in any other State to be a frivolous
litigant or subject to an Order precluding me from serving and filing this document.
c. I am not serving or filing this document for any improper purpose, such as to harass the other
party or to cause delay or needless increase in the cost of litigation or to commit a fraud on the
court.
d. I understand that if I am not telling the truth or if I am misleading the court or if I am serving or
filing this document for any improper purpose, the court can order me to pay money to the other
party, including the reasonable expenses incurred by the other party because of the serving or
filing of this document such as court costs, and reasonable attorney fees.
�--
Subscribed and sworn to before me this
Signature
Sign only in presence of otary or court clerk
! `� day of ��'�� ,20 r 3 Street address:
� ��iC Bi+�kke City/State/Zip: � � 4-� ��_�� ���� )
Notary Public/Deputy Clerk ���►1I3t1"flt01' Telephone C�Jt�7 -
State of Minnesota District Court, 2`� Judicial District
Counry of Ramsey Case No.��o�c�f 3� ��-b
Case Type: Criminal
STATE OF MINNESOTA
V Affidavit of Service
�� � s� ����
Name of Defendant/Respondent
STATE OF MIN�SOTA )
COUNTY OF � ) SS
(County where Affidav� Signed)
I, r � wc.t,l `�c7� 1J � , being duly sworn, upon oath, state that
(Name of person who hand-delivered or mailed documents)
on , I served the attached documents, namely
(Date documents hand delivered or mailed)
the Notice of Motion & Motion to Reouen Case upon Plaintiff by Personal service
(handing a true and correct copy of the documents) to the:
St. Paul City Clerk's O�ce
--or—
City Attorney's Office (Suburban Prosecutor)
(Name of City/Jurisdiction)
Subscribed and sworn to
before me this day Signature of Person Who Delivered or Mailed Documents
Of , 20 (Sign only in presence of notary public or clerk of court)
Street address
Notary Public/Deputy Clerk City/State/Zip
Telephone( )