Case 2023CF000042 Document 62 Filed 07-24-2023 Page 1 of 2

FILED
07-24-2023
Clerk of Circuit Court
Brown County, WI
STATE OF WISCONSIN CIRCUIT COURT BROWN COUNTY
2023CF000042
______________________________________________________________________________

STATE OF WISCONSIN,
Plaintiff, Case No. 23CF42

Maylia Julieanna Paige Sotelo,

Defendant.
______________________________________________________________________________

NOTICE OF MOTION
AND MOTION TO STAY TRIAL PROCEEDINGS
______________________________________________________________________________

To: Brown County District Attorney David Lasee, or designee,

300 E Walnut St
Green Bay, WI 54301

PLEASE TAKE NOTICE, the defendant Maylia Julieanna Paige Sotelo, by her attorney
Trisha Janet Fritz, moves the Honorable Beau Liegeois, pursuant to Rule §808.07(2) of the
Wisconsin Statutes, for entry of an order staying proceedings in the trial court during the
pendency of an appeal, based upon the following grounds:

1. On July 17, 2023, the Honorable Beau Liegeois denied a reverse waiver petition in
23CF42 maintaining the juvenile defendant in adult court.
2. The next court date in this matter is scheduled for September 18, 2023 at 9:00 am for
a status.
3. A petition for leave to file an interlocutory appeal under §808.03(2) will be filed with
the Wisconsin Court of Appeals, District Three.
4. The entry of the written order from Judge Liegeois on July 18, 2023, triggers a 14-
day deadline for filing the petition for leave to appeal.
5. After the defendant files its petition, the State has 14 days to file a response.
6. Continuing with this matter at the trial court level while the Court of Appeals
considers Ms. Maylia Julieanna Paige Sotelo’s petition may interfere with the appeal.
Case 2023CF000042 Document 62 Filed 07-24-2023 Page 2 of 2

7. Acceptance of Ms. Maylia Julieanna Paige Sotelo’s petition by the Court of Appeals
may result in a reversal of the Order entered by the court, requiring a new hearing on
the reverse waiver matter.
8. The defendant will suffer irreparable injury if the requested stay is denied.
9. Since this is an interlocutory appeal, the length of delay created by any stay will not
be onerous.
10. Neither the State of Wisconsin nor the public interest will be harmed if the requested
stay is granted.

Dated this 23rd day of July, 2023.

Respectfully Submitted,

Electronically signed Trisha Janet Fritz

Atty. Trisha Janet Fritz
Attorney for the Defendant
State Bar No. 1093722

Hogan Eickhoff SC
1775 Margaret St
Appleton, WI 54913
(920) 450-9800
Trisha.fritz@hoganeickhoff.com