The following excerpt is from United States v. Richards, No. 17-2112-cr (2nd Cir. 2019):
Finally, the district court did not err in declining to hold an evidentiary hearing before deciding the motion. "A defendant is not entitled to an evidentiary hearing as a matter of right whenever he seeks to withdraw his guilty plea." United States v. Gonzalez, 970 F.2d 1095, 1100 (2d Cir. 1992). Instead, "the defendant must present some significant questions concerning the voluntariness or general validity of the plea to justify an evidentiary hearing." Id. For the reasons already discussed, Richards did not present any significant questions concerning the voluntariness or general validity of his plea.
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