Abdi ��
State of Minnesota District Court, 2"d Judicial District
County of Ramsey Case No. ��C� /�Q �� �1� 7
����,5,�����Case Type: Criminal
STATE OF MINNESOTA SEt� 2 e 2O�z
� ������ ,�°����' Notice of Motion and Motion
� '� l , S\ • To Reopen Case
�-�'�I�' �cd � �' �
Name of Defendant(s)/Respondent(s)
TO: Plaintiff
. To be completed by Heari�g Officer:
PLEASE TAKE NOTICE THAT on at o'clock .m
(Date of Hearing) (tlme of hearing)
Before . Judge of the District Court, in Room located at
Name of Judge or Referee ,
❑ 15 V4'�st KeNogg Blvd in the City Hall/ Courtho�se ir the City of St. Paul, State of Minnescta, 55�02
i7 2050 Vyhite �ear Ave./ Courtti�use in the Ci'�y� of �lap;ewood, State of Mirnesota, 55109 I
I will ask the Court for an Order as follows
MOT�ON,
I am asking the Court to g�ant 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):
s ��,�. r � � .�� G �, �� � I � I � 2 R
T�-. ; - .�� =e.e. �.,1� d �'L ��
`� �..>�� '� � � � �, t,�:�-�,
�n,c-���a�� � ' �13 ��-�v� o r2 � 1� I l Z �
3. Verifrcafion and Acknowledgements:
a. I have read this document. To the best of my knowledge, information and betief the information
eontained in this document is well grounded in fact and is warra�ted bK 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 a� 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 tliis 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 reasona6le attorne fees.
Subscribed and sworn to before me this Signature_
� Sign only in presence of notary or court clerl�
���day of 20 �� Street address: �t/�S ) �Ssli�vc,'y� /�-,YL 1.�
CO 11 �C City/State/Zip: .5�.�a,t.t� ; /L►t'U� �,S/G �
Notary Public/Depury Cle k mm strafor Telephone (�) 2G5—' -�'/� Z �
, r
J �
State of Minnesota District Court, 2"d ]udicial District
County of Ramsey Case No.
Case Type: Criminal
STATE OF MINNESOTA
� Affidavit of Service
S�� ����s�� ����
Name of Defendant/Respondent
. STATE OF MINNESC�TA )
COUNTY Oi= ) SS
(Courtty H•here Affidavit Signed)
I� being duly swor�; upon oath,
(Name of person who hand-delivered or mailed documents)
state that on I served the attached documents, namely
(Date documen*s hand oel±vered or maile�
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 Gty/)urisdiction)
Subscribed and sworn to
befare me this C�dy Signature of Person Who Delivered or Matled Documents
Of , 20 (Sign only in presence of notary public or clerk of court)
Street acJdress
Notary Public/Deputy Clerk City/State/Zip
Telephone( )