Notice of Explanation and Certification to the Court — United States v. Baver (Dkt. 277, D. Utah)

Summary

A Notice of Explanation and Certification to the Court in United States of America v. Allison Marie Baver, Case No. 2:21-cr-00520, in the U.S. District Court for the District of Utah, filed July 21, 2025. Defense counsel Alexander E. Ramos and Nicolas C. Wilde state that the Rule 33 motion deadline is that day, that the motion has been finalized, and that counsel filed a motion to withdraw the same day because of a fundamental disagreement. The notice states that filing the Rule 33 motion now could lead to ineffective assistance claims and prevent the defendant or new counsel from amending it. Counsel states that he must withhold filing until the withdrawal motion is resolved.

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Case 2:21-cr-00520-JNP               Document 277           Filed 07/21/25       PageID.4131    Page 1 of 2




 Michael Langford (9682)
 Alexander E. Ramos (15234)
 LANGFORD | RAMOS PLLC
 43 E. 400 S.
 Salt Lake City, UT 84111
 Telephone: (801) 998-2002
 Email: mjl@langfordramos.com
 Email: alex@langfordramos.com

 Nicolas C. Wilde (15768)
 Law Office of Nicolas C. Wilde LLC
 40 S. 600 E.
 Salt Lake City, Utah 84102
 T. 801-949-3088
 nick@ncwildelaw.com

 Attorneys for Defendant Allison Marie Baver


                              IN THE UNITED STATES DISTRICT COURT
                                        DISTRICT OF UTAH


     UNITED STATES OF AMERICA,                                Notice of Explanation and Certification to
                                                                              the Court
          Plaintiff,

     v.                                                       Case No. 2:21-cr-00520

     ALLISON MARIE BAVER                                      District Judge Jill N. Parrish

          Defendant.                                          Magistrate Judge Cecilia Romero


             Ms. Baver’s Rule 33 motion deadline is today. Counsel certifies that the motion was

 finalized on July 14, 20251. Due to a fundamental disagreement, counsel filed a motion to

 withdraw today. Filing the Rule 33 motion now could lead to ineffective assistance claims and

 prevent Ms. Baver, or new counsel, from amending it. Counsel faces a dilemma: not filing

 violates the Court's order, while filing could disadvantage Ms. Baver. Counsel believes he must



 1
     Counsel has saved a PDF copy should the Court require a copy.

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Case 2:21-cr-00520-JNP        Document 277       Filed 07/21/25      PageID.4132       Page 2 of 2




 withhold filing until the withdrawal motion is resolved. This is the only way counsel can uphold

 his duty to Ms. Baver.



        RESPECTFULLY SUBMITTED this July 22, 2025.

                                                            Alexander E. Ramos
                                                            LANGFORD RAMOS, PLLC
                                                            /s/ Alexander E. Ramos




                                                            /s/ Nicolas C. Wilde
                                                            Nicolas C. Wilde
                                                            Law Office of Nicolas C. Wilde LLC

                                                            Attorneys for Defendant




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