Court filing
Notice of Intent to Withdraw Guilty Pleas — Carl Bradley Johansson
No. 5:21-cr-00170-JGB · Doc. 102 · Docket on CourtListener
Full text
Case 5:21-cr-00170-JGB Document 102 Filed 11/23/22 Page 1 of 4 Page ID #:860
EDWARD M. ROBINSON (CA Bar 126244)
1 Brian A. Robinson (CA Bar 333650)
21515 Hawthorne Blvd, Suite 730
2 Torrance, CA 90503
Office: (310) 316-9333
3 Facsimile: (310) 316-6442
eroblaw@gmail.com
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Attorneys for Defendants
5 Carl Bradley Johansson
National Distribution, Inc.
6 Western Distribution, LLC.
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8 UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
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12 UNITED STATES OF AMERICA, Case No. 5:18-00114-VAP
Case No. 5:21-00170-VAP
13 Plaintiff,
DEFENDANTS CARL BRADLEY
14 v. JOHANSSON’S, NATIONAL
DISTRIBUTION INC.’S, AND
15 NATIONAL DISTRIBUTION, INC., et WESTERN DISTRIBUTION,
al., L.L.C.’S NOTICE OF INTENT TO
16 WITHDRAW GUILTY PLEAS;
Defendant. DECLARATION OF COUNSEL
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DATE: November 29, 2022
18 TIME: 10:00 a.m.
Courtroom of the
19 Honorable Virginia A. Phillips
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Case 5:21-cr-00170-JGB Document 102 Filed 11/23/22 Page 2 of 4 Page ID #:861
1 PLEASE TAKE NOTICE that Defendants Carl Bradley Johansson (“Mr.
2 Johansson”), National Distribution, Inc. (“National”) and Western Distribution, LLC.
3 (“Western”), by and through their attorneys of record Edward M. Robinson and Brian
4 A. Robinson, hereby gives notice of their intent to move this Court to Withdraw their
5 pleas to counts 3, 4, 5, 6, 8 and 9 (“tax counts”) in case number 5:18-cr-00114-VAP
6 (“114”) and counts 1-4 (“bank fraud counts”) in case number 5:21-cr-00170-VAP
7 (“170”). (Case No. 114, Doc. 264; Case No. 170, Doc. 32.)
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9 Respectfully submitted,
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DATED: November 23, 2022 By /s/ Edward M. Robinson
12 Edward M. Robinson
Brian A. Robinson
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Attorneys for Defendant
14 Carl Bradley Johansson
National Distribution, Inc.
15 Western Distribution, LLC.
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Case 5:21-cr-00170-JGB Document 102 Filed 11/23/22 Page 3 of 4 Page ID #:862
1 DECLARATION OF EDWARD M. ROBINSON
2 I, Edward M. Robinson, hereby declare as follows:
3 1. That I am the attorney of record in Case Numbers 5:18-00114-VAP
4 (“114”) and 5:21-00170-VAP (“170”) on behalf of Carl Bradley Johansson (“Mr.
5 Johansson”), National Distribution, Inc. (“National”), and Western Distribution, LLC.
6 (“Western”).
7 2. That on November 6, 2022, Mr. Johansson and National moved to
8 withdraw their guilty pleas in case number 114, specifically to counts 1 and 2. (Doc.
9 389, 390). At that time, Mr. Johansson did not move to withdraw his pleas to the Tax
10 Evasion counts in case number 114 and did not move to withdraw his please to
11 Conspiracy to Commit Bank Fraud and Bank Fraud in case number 170. Western has
12 not moved to withdraw its pleas to any counts in case number 170. (Case No. 114, Doc.
13 264; Case No. 170, Doc. 32.)
14 3. Yesterday, on November 22, 2022, I met with Mr. Johansson at MDCLA.
15 At this meeting, Mr. Johansson expressed his desire and intention to move to withdraw
16 his pleas to the tax counts in case number 114 and the bank fraud counts in case
17 number 170. Mr. Johansson was unequivocal in his intent and request that the motion to
18 withdraw be made as to those counts.
19 4. The sentencing and motion date is currently set for November 29, 2022.
20 5. I have attempted to make contact with AUSA Matthew O’Brien to inform
21 him of the filing of this notice. I have not been able to reach him.
22 6. Based on this new information, on behalf of Mr. Johansson, National and
23 Western, I intend to request a continuance of the motion and sentencing dates currently
24 set for November 29, 2022, so that I may have the opportunity to adequately brief Mr.
25 Johansson’s new request to withdraw his please to the tax counts in case number 114
26 and to the bank fraud counts in case number 170.
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Case 5:21-cr-00170-JGB Document 102 Filed 11/23/22 Page 4 of 4 Page ID #:863
1 I declare under penalty of perjury that the foregoing is true and correct to the best
2 of my knowledge.
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4 Executed on November 23, 2022, in Torrance, California.
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7 By /s/ Edward M. Robinson
Edward M. Robinson
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Attorney for Defendant
9 Carl Bradley Johansson
National Distribution, Inc.
10 Western Distribution, LLC.
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