Parker State of Minnesota District Court, 2"d Judicial District
County of Ramsey Case No. �d �
Case Type: Crimina
STATE OF MINNESOTA
� Notice of Motion and Motion
To Reopen Case
� � � �� � �
Name of Defendant )/Respondent(s) ���i�����'�
TO: Plaintiff N0� �$ 2��3
To be completed by Hearing Officer: CITY CLER
PLEASE TAKE NOTICE THAT on �� �\� at '��_o'clock�.m
(Date of Hearing) (time of hearing)
Before , ]udge of the District Court, in Room located at
Name of Judge or Referee
T�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
following reasons: (tell the Court why you are asking for your requests):
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3. Veri�cation 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 parly because of the serving or
fifing of this document such as court costs, and reasonable attorney fees.
Signatur ��
Subscribed and sworn to before me this �
Sign only In presence of notary co rt clerk
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STATE OF MINNESOTA )
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COUNTY OF RAMSEY_ )
AFFIDAVIT OF SERVICE
Erin M. Lembke, being duly sworn and deposed, says that on November 15, 2013, she
served a copy of the attached: Notice of Motion and Motion To Reopen Case (State of
Minnesota vs. Jeffery James Parker) upon Robb Olson, located at 4770 White Bear Parkway,
White Bear Lake, MN 551 l Oby sending through US Mail a true correct copy thereof.
Signed:
Subscribed and sworn before me
on�this 15 day ofNo m e , 2013.
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^ otary Public
�°'`"=��..,� CHRISTINE M. RUED
�. r� Notary Publio-Minnesota
'�;...._j�s'°�My Commission F�ires Jen 31.2015