SUMMARY SERVICES

 

Robert J. Beles  Bar No. 41993

1 Kaiser Plaza, Suite 1750

Oakland, California 94612

Tel No. (510) 836-0100

Fax. No. (510) 832-3690

 

Demetrius Costy

Attorney for Defendant

 

 

SUPERIOR COURT OF CALIFORNIA, COUNTY OF ALAMEDA

RENE C. DAVIDSON COURTHOUSE

 

People of the State of California,

 

                        Plaintiff,

 

            vs.

 

 

Jane Doe,

 

                        Defendant.

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No.   H-13919

 

Date:

Time:

Department:

 

NOTICE OF MOTION AND MOTION TO REDUCE DEFENDANT'S FELONY CONVICTION TO A MISDEMEANOR; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF DEFENDANT JAND DOE; ORDER

 

NOTICE OF MOTION AND MOTION TO REDUCE DEFENDANT'S FELONY CONVICTION TO A MISDEMEANOR

 

To the District Attorney of Alameda County, and to his deputy:

            Defendant, Jane Doe, has scheduled a hearing on __________________________,

at _______.M., in Department ___9 of the Alameda County Superior Court.  On that date and time, she will move for the court to reduce his felony conviction to a misdemeanor, and to notify the California Department of Justice pursuant to Penal Code section 13151.

            Defendant bases her motion on Penal Code sections 17(B)(3) the equitable power of the court to strike convictions in the interest of justice, and the following facts, that she has successfully completed the terms of probation, is not serving a sentence, is not on probation, and is not charged with any new offense, and has not been in trouble since the conviction.

            This application is based on the attached memorandum of points and authorities, the attached declaration, all papers filed and records in this action, evidence taken at the hearing on this motion, and argument at that hearing.

            Wherefore, defendant respectfully requests this Court to grant the application and notify the California Department of Justice of this action.

            Dated:  Oakland, California, _______________