Ernest Warren, Jr., OSB #891384 

E-Mail: e.warren@warrenpdxlaw.com 

Warren & Sugarman 

838 SW First Avenue, Suite 500 

Portland, Oregon 97204 

Tel: (503) 228-6655 

Fax: (503) 228-7019 

Attorney for Defendant Eric Lee Flores 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF OREGON 

PORTLAND DIVISION 

UNITED STATES OF AMERICA, Case No. 3:16-cr-00051-BR 

v. 

ERIC LEE FLORES, 

Plaintiff, 

Defendant. 

MOTION FOR WITHDRAW AL OF 

GUILTY PLEA 

CERTIFICATE OF CONFERRAL 

Pursuant to this Court's order, the parties have conferred and the government by and 

th.rough AUSA Craig Gabriel objects to the relief requested. 

MOTION 

COMES NOW the defendant, Eric Lee Flores, by and th.rough his attorney, Ernest 

Warren, Jr., and moves the Court for an order allowing the defendant to withdraw his plea of 

guilty because he has newly discovered evidence, that was presented in the trial of codefendants, 

that if known to the defendant would have persuaded him not to plead guilty in this case. This 

Page 1 -MOTION FOR WITHDRAWAL OF GUILTY PLEA 

WARREN & SUGARMAN 

Attorneys at Law 

838 SW First Avenue• Suite 500 •Portland. Oregon 97204 

Tel (503) 228-6655 •Fax (503) 228-7019 e. warren@warrenpdxlaw.com 

Case 3:16-cr-00051-BR Document 1553 Filed 11/08/16 Page 1 of 3
newly discovered evidence included the testimony and statements of confidential informants who 

were encouraging others to violate the law and escalate confrontations with federal officers 

unnecessarily. 

Additionally, the presentation of the testimony and statements of confidential informants 

in the codefendants trial was a substantial factor in the acquittals of the codefendants before a 

jury. This evidence is newly discovered by the defendant, and supplies a fair and just reason for 

defendant's withdrawal of his guilty plea. 

Points and Authorities 

Fed. R. Crim. P. 1 l(d)(2)(B) 

DATED this 8111 day of November, 2016. 

RESPECTFULLY SUBMITTED, 

/s/ Ernest Warren, Jr. 

Ernest Warren, OSB No. #891384 

Attorney for defendant 

Page 2 - MOTION FOR WITHDRAWAL OF GUILTY PLEA 

WARREN & SUGARMAN 

Attorneys at Law 

838 SW First Avenue • Suite 500 • Portland. Oregon 97204 

Tel (503) 228-6655 •Fax (503) 228-7019 e. warren@warrenpdxlaw.com 

Case 3:16-cr-00051-BR Document 1553 Filed 11/08/16 Page 2 of 3
CERTIFICATE OF SERVICE 

I hereby certify that I have served the MOTION FOR WITHDRAW AL OF GUILTY 

PLEA AND DECLARATION IN SUPPORT OF MOTION FOR WITHDRAW AL OF 

GUILTY PLEA in the attached matter upon the parties listed below by notice of electronic 

filing using the CM/ECF System as follows: 

Ethan D. Knight 

Craig J. Gabriel 

Geoffrey A. Barrow 

U.S. Attorney's Office 

District of Oregon 

1000 S.W. Third Avenue 

Suite 600 

Portland, OR 97204 

503-727-1000 

Fax: 503-727-111 7 

a:nd ·filed the original with the Court on the date listed below. 

DATED this 8111 day of November, 2016. 

WARREN & SUGARMAN 

IS/ Ernest Warren, Jr. 

Ernest Warren, Jr. OSB No. 891384 

Attorney for defendant 

Page 3 - MOTION FOR WITHDRAWAL OF GUILTY PLEA 

WARREN & SUGARMAN 

Anomeys at Law 

838 SW First Avenue • Suite 500 • Portland. Oregon 97204 Tel (503) 228-6655 • Fax (503) 228-70f9 e.warren@warrcnpdxlaw.com 

Case 3:16-cr-00051-BR Document 1553 Filed 11/08/16 Page 3 of 3