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Smith, Theresa L ` State of Minnesota �E���-��`��� District Co�rt, 2�d Judicial District County of Ramsey ��� 1 6 201?ease No. �-Zc� aoc�590Li—1 ��-�.� �,� ���ase Type: Criminal STATE OF MINNESOTA � Notice of Motion and Motion _ To Reopen Case �TrQa�e� �n ��l Name of Defendant(s)/Respondent(s)� TO: Plaintiff To be completed by Hearing Officer: PLEASE TAKE NOTICE THAT an 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 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): � � Ci(.t-�2_ � � �7 i ' �' -� GJ C� �, ��c ���x- % n 4-k�ror,J �►+h�r � cvy�r, r.e,x c�Po,'m�n-f C�.vr�. �-�� �"%G� �-' 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 need�ess 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 filing of this document such as court costs, and reasonable attorney fees. Subscribed and sworn to before me this Signatur l ign onl presence of notary or court clerk �_day of �►a�..st ,20� Street address:� �*'(,�/�t�ohC3?"• ��� City/State/Zip: �. � Gif �/V o��� y. ` Notary ubl' e u Telephone (�� `�� - "�7-��� , _ State of Minnesota District Court, 2"d Judicial District County of Ramsey Case No. Case Type: Criminal STATE OF MINNESOTA V Affidavit of Service Name of Defendant/Respondent STATE OF MINNESOTA ) COUNIY OF ) SS (County wliere Affidavit Signed) I, , being duly sworn, upon oath, (Name of person who hand-delivered or mailed documents) state that on , I served the attached documents, namety (Date documents hand delivered or mailed) the Notice of Motion & Motion to Reopen Case upon Plaintiff by Personal service (handing a true and correct copy of the documents) to the: � St. Paul City Clerk's Office --or— City Attorney's Office (Suburban Prosecutor) (Name of Ciry/Jurisdiction) Subscribed and sworn to before me this ddy Sig�ature 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 (_)