California, United States of America
The following excerpt is from People v. Moreno, E056441 (Cal. App. 2013):
A defendant who has entered a guilty plea may move to withdraw the plea, upon a showing of good cause, at any time before judgment has been entered. (People v. Sandoval (2006) 140 Cal.App.4th 111, 123.) Here, judgment was entered on April 11, 2012, the date defendant was sentenced. Therefore, counsel was correct that the trial court on June 1, 2012, was without jurisdiction to hear such a motion.
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