Application for Order and Proposed Order to Withdraw Guilty Plea — United States v. William Nguyen

Summary

Application and proposed order to withdraw guilty plea in United States v. William Nguyen, No. CR 24 00555 SI, in the United States District Court, Northern District of California, filed June 10, 2026. The defendant asks permission to withdraw the previously entered guilty plea pursuant to the terms of the Plea Agreement (Docket #20), stating that all requirements of the LEADS program have been satisfied as confirmed by a Status Memorandum from United States Pre Trial Services dated June 1, 2026. The application states that the government has no objection. The proposed order states that the previously entered plea of guilty is set aside and that the Court anticipates the United States will file a motion to dismiss the indictment with prejudice upon successful completion of the LEADS Program.

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Full text

     Case 3:24-cr-00555-SI                Document 34   Filed 06/10/26   Page 1 of 2



 1 HARRIS B. TABACK, California Bar No. 111017
   Law Offices of Harris B. Taback
 2 345 Franklin Street, Suite 102
   San Francisco, CA 94102
 3 (415) 241-1400
   Email: htaback@earthlink.net
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   Attorney for Defendant
 5 WILLIAM NGUYEN
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                                     UNITED STATES DISTRICT COURT
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                                   NORTHERN DISTRICT OF CALIFORNIA
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                                            SAN FRANCISCO DIVISION
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                                                          )
13 UNITED STATES OF AMERICA,                              )
                                                          )   No.   CR 24 00555 SI
14                           Plaintiff,                   )
                                                          )   APPLICATION FOR ORDER AND
15                     vs.                                )   PROPOSED ORDER TO WITHDRAW
                                                          )   GUILTY PLEA PURSUANT TO
16 WILLIAM NGUYEN,                                        )   TERMS OF PLEA AGREEMENT
                                                          )   WITHOUT OPPOSITION FROM THE
17                           Defendant.                   )   GOVERNMENT
                                                          )
18                                                        )

19        COMES NOW DEFENDANT WILLIAM NGUYEN, by and through undersigned Counsel,
20 who respectfully requests permission to withdraw his previous entered guilty plea in the present
21 charged matter. This request is made pursuant to the terms of the Plea Agreement (Docket #20)
22 as all requirements of the LEADS program have been satisfied as has been confirmed by the Status
23 Memorandum recently submitted by United States Pre Trial Services dated June 1, 2026 (Docket
24 #33). The Government was informed Counsel that it has no objection to this request. Counsel so
25 states under penalty of perjury.
26        //////////
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     Case 3:24-cr-00555-SI       Document 34       Filed 06/10/26     Page 2 of 2



 1 Dated: June 10, 2026                            Respectfully Submitted,
 2                                                 LAW OFFICES OF HARRIS B. TABACK
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                                                   By:____________//HBT//__________________
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                                                   HARRIS B. TABACK
 6                                                 Attorney for Defendant WILLIAM NGUYEN
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 9                                     [PROPOSED] ORDER

10       GOOD CAUSE APPEARING, AND WITHOUT OBJECTION, IT IS HEREBY
     ORDERED THAT the previously entered plea of guilty is set aside. The Court anticipates
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     that The United States, according to the terms of the Plea Agreement and upon successful
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     completion of the LEADS Program, will file a motion to dismiss the indictment with prejudice.
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     Dated: June__________, 2026
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                                                   ____________________________________
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                                                   THE HONORABLE SUSAN ILLSTON
17                                                 UNITED STATES MAGISTRATE JUDGE
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