California, United States of America
The following excerpt is from People v. Matias, F070079 (Cal. App. 2015):
"A defendant must obtain a certificate of probable cause in order to appeal from the denial of a motion to withdraw a guilty plea, even though such a motion involves a proceeding that occurs after the guilty plea." (People v. Johnson (2009) 47 Cal.4th 668, 679.)
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