Simmons, 164 Ill. App. 3d 205 (1987) (motion to withdraw guilty plea pursuant to Rule 604(d));
In re Marriage of Morse, 143 Ill. App. 3d 849 (1986) (posttrial motion pursuant to section 2-
1203 of the Code of Civil Procedure (Ill. Rev. Stat. 1983, ch. 110, par. 2-1203)); People v.
Easley, 199 Ill. App. 3d 179 (1990) (motion for reduction of sentence); Pagel, 197 Ill. App. 3d at
308 (date of proof of service, not postmark date, determines when motion to withdraw guilty plea
is filed); People v. Johnson, 232 Ill. App. 3d 882 (1992) (postconviction petition).
Our review of the case law pertaining to the “date of mailing” rule thus establishes that if
a notice of appeal or any paper required to be filed in the reviewing court is filed by mail and
received after the due date, then the date of mailing is deemed to be the date of filing. More
importantly for purposes of the issue before us on appeal, proof of mailing under these
circumstances is established by filing a proof of service that complies with the requirements of
Rule 12(b)(3). Thus, Rule 12(b)(3) does not apply only to proof of service on a party, as
defendant contends, but rather the rule also governs the manner by which a party proves that it
mailed a notice of appeal or any paper filed in the reviewing courts when that party is relying
upon the date of mailing as the date of filing.
We therefore conclude that when a defendant’s motion to withdraw a guilty plea is
received by the circuit court after the 30-day time period, and the defendant is thereafter relying
upon the date of mailing as the date of filing, proof of mailing shall be as provided by Rule
12(b)(3). As the case law discussed above makes clear, in each situation in which our supreme
court has applied the “date of mailing” rule, the court has also required that proof of mailing
“shall” be as provided by Rule 12(b)(3). (Emphasis added.) 155 Ill. 2d R. 373. We can discern
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