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Martinez, Abigail State of Minnesota � �.�-�� ;.�� District Court, 2�d Judicial District ��.��..:s . ...,. �� County of Ramsey � � � Case No. �2 0°J t�OcI3 a--S� ��'� `"� �� Case Type: Criminal �I I �t' C.L�r�$� STATE OF MINNESOTA � Notice of Motion and Motion To Reopen Case �`Gfi9 � `�� Name of Defend nt(s)/Respondent(s) TO: Plaintiff To be completed by Hearing Officer: PLEASE TAKE NOTICE TNAT on at o'clock_.m (Date of Hearing) (time 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 following reasons: (tell the Court why you are asking for your requests): 1 l,�� `�C� �1��('� �� c.�-��1G2�[ C�(� wv� '�/�C ti`t-V1P � r��-P Y1,�1 C-e- 1I�I �i�P Y'�� 3. Verification ancl 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 resence otary or court clerk Z�day of �� ,20�� Street address: ��,�T✓�G1�G��'� City/State/Zip: ��/ . ��1� S�l�� ota Publ c/De u C erk �ngen Telephone (�) ZQ � � �'Y p � Deputy Court Administrator State of Minnesota , •- .�., � � �-__iDistrict Court, 2"d Judicial District f��:��.,.� ��'�� q � f ��r I ��( `7 County of Ramsey �, �1 Case No. �Z� ��P �� Case Type: Criminal STATE OF MINNESOTA �i.�� C�� V Notice of Motion and Motion To Reopen Case �f��L� Ul v��,�� Name of efendant s)/Respondent(s) TO: Plaintiff To be completed by Hearing Officer: PLEASE TAKE NOTICE THAT on at o'clock_.m (Date of Hearing) (time of hearing) Before , Judge of the District Court, in Room located at Name of Judge 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 Ciy 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 t'2d50115: (tell the Court why you are asking for your requests): i I,{��a S c�1�Q I��►�P �� r�-�-f—�� n� r _ ��'t��i��, �� l� Y1��zP �Y, � �'l� �� / 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 notary or court clerk 2tU day of '1�-2� ,20 �' _ Street address: ti �� N� a� � - Taylor Swearingen ciry/state/zi : v � 'ni�tratar Notary Pub� Deputy Clerk Telephone ( ) 2 z{� �Z7 State of Minnesota District Court, 2"d Judicial District ��.��:�a�:�� °� Ov� 3� � � <° County of Ramsey � ,� �1 Case No. �� :,6 r:�� Case Type: Criminal STATE OF MINNESOI��p�� '�-�r�� Notice of Motion and Motion , To Reopen Case � �� , d� �� Name of fendant( )/Respondent(s) TO: Plaintiff To be completed by Hearing O�cer: PLEASE TAKE NOTICE THAT on at o'clock_.m (Date of Hearing) (time of hearing) Before , Judge of the District Court, in Room located at Name of Judge or Referee O 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��OW111CJ I"ea50115: (tell the Court why you are asking for your requests): j i A Jf�� )i�Gl I�s��V� �;t `�,l' ��} ��C�1�1 C:)'�, ��G� �'� `C�'�'i�r�'v'P 1�� j,c� lV1 � V�<�c i� 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 1 �� Sign only in resence of not ry or court clerk 2�P day of`-x�P-�f''� �el� ,20 � � Street address: � � ` City/State/Zip: �� ?v Notary Pub� Deputy Clerk-ray�pr SW8a�n9 n Telephone ) �� - �� — ��.,,�rt„��pdministrator