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RE: Motion to Withdraw Guilty Plea



A case file is on its way to you.  The case name is Mahfouz.  Please let me know if you need access to a research website that includes Michigan laws and cases.  What I want you from you is memorandum of law that answers the following questions:

 

1.        Whether the late filing of the appeal by the appellate counsel resulted in prejudice to the substance of the case?  What I mean by that is was the late filing harmless error or was malpractice committed by the late filing that prejudiced the client’s opportunity to have his guilty plea set aside?

2.       Whether a claim for ineffective assistance of counsel lies against defense trial counsel for failing to advise the client that he would have to register as a sex offender?

3.       Whether the plea can be set aside upon a showing that trial defense counsel coerced his client into pleading guilty?

4.       Whether Michigan law allows a guilty plea to be set aside for any reason?

5.       Whether we are still within the window of opportunity to file such a claim if Michigan law allows it?

 

Please manage your time to spend no more than 12 hours on answering these questions.  The rate for the work is $50 per hour.  If you find that based on the status of the law in Michigan we can make a good faith challenge to the guilty plea to withdraw it or set it aside, I will engage the client to fund the additional work.

 

Thank you

 

From: Jacqueline Black [mailto:jacquelinerblack@gmail.com]
Sent: Tuesday, October 25, 2011 7:47 PM
To: Haytham Faraj
Subject: Re: Motion to Withdraw Guilty Plea

 

Sorry for the delay:

 

Jacqueline Black

4908 Cape May Avenue
San Diego, CA 92107

On Mon, Oct 24, 2011 at 7:53 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote:

Hi Jackie,

Please send me your mailing address. 

 

From: Jacqueline Black [mailto:jacquelinerblack@gmail.com]
Sent: Sunday, August 28, 2011 6:19 PM
To: Haytham Faraj
Subject: Re: Motion to Withdraw Guilty Plea

 

Dear Mr. Faraj: 

 

I just wanted to check in, I'm sure you had a lot to catch up on after your vacation. I'd be happy to assist you with the motion (or any other projects you may need assistance with) at your convenience. 

 

Best, 

 

Jackie

On Mon, Aug 15, 2011 at 7:13 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote:

Yes. I will. I'll call Wednesday after I meet with the client. 

Haytham Faraj 

Sent from my iPhone


On Aug 11, 2011, at 12:32 PM, Jacqueline Black <jacquelinerblack@gmail.com> wrote:

Dear Mr. Faraj:

 

Hope you enjoyed a wonderful vacation. Please let me know if you need any assistance with the motion. I am more than happy to help.

 

 

Best,

 

Jackie

On Mon, Jul 18, 2011 at 12:51 AM, Haytham Faraj <haytham@puckettfaraj.com> wrote:

I'm overseas until the 26th. I'll call you when I return.

Haytham Faraj
Sent from my iPad


On Jul 14, 2011, at 5:04 PM, Jacqueline Black <jacquelinerblack@gmail.com> wrote:

> Dear Mr. Faraj:
>
> I hope you are enjoying your vacation.  I apologize for not responding sooner. I was out of town last week and hadn't checked my messages. I would be more than happy to help with the motion. Please let me know the details at your convenience.
>
>
> Safe travels,
>
> Jackie