Free Motion to Withdraw Plea of Guilty - District Court of California - California

Case 3:07-cr-03117-LAB
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 v. EDGAR LEONEL NATAL Defendant. Attorneys for Defendant Natal

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STEVEN L. BARTH California Bar No. 224185 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 San Diego, California 92101-5008 Telephone: (619) 234-8467

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE LARRY A. BURNS) UNITED STATES OF AMERICA, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) CASE NO. 07CR3117-LAB Date: April 7, 2008 Time: 1:30 p.m. NOTICE OF MOTION AND MOTION TO: (1) WITHDRAW GUILTY PLEA

TO: KAREN HEWITT, UNITED STATES ATTORNEY, AND MICHELLE PETTIT, ASSISTANT UNITED STATES ATTORNEY: PLEASE TAKE NOTICE that Defendant EDGAR LEONEL NATAL, by and through his attorneys, Steven L. Barth and Federal Defenders of San Diego, Inc., hereby asks this Court to enter an order granting the following motion. // // // // // // // 07CR3117

Case 3:07-cr-03117-LAB
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 21, 2008

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MOTION Defendant Edgar Leonel Natal, by and through his attorneys, Steven L. Barth and Federal Defenders of San Diego, Inc., moves this Court pursuant to the United States Constitution, the Federal Rules of Criminal Procedure, and all other applicable statutes, case law, and local rules for an order: (1) Withdrawing his guilty plea.

This motion is based upon the instant motion and notice of motion, the attached statement of facts and memorandum of points and authorities, the files and records in the above-captioned matter, and any and all other materials that may come to this Court's attention prior to or during the Court's consideration of this motion. Respectfully submitted, /s/ Steven L. Barth STEVEN L. BARTH Federal Defenders of San Diego, Inc. Attorneys for Mr. Natal

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07CR3117

Case 3:07-cr-03117-LAB
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 21, 2008

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her information and belief, and that a copy of the foregoing document has been served this day upon: Michelle Pettit Office of the United States Attorney 880 Front Street Room 6293 San Diego, CA 92101 (619)557-6747 Email: [email protected] Respectfully submitted, /s/ Steven L. Barth STEVEN L. BARTH Federal Defenders of San Diego, Inc. Attorneys for Mr. Natal

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