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no reason why the same requirement regarding Rule 12(b)(3) would not also apply to a motion to
withdraw a guilty plea when a defendant is relying upon the “date of mailing” rule to establish
that such a motion was timely filed. Adopting such a requirement is therefore consistent with the
supreme court rules and would also maintain a uniform body of precedent in that proof of
mailing documents to the reviewing court, proof of mailing a notice of appeal, and proof of
mailing a motion to withdraw a guilty plea would all be as provided by Rule 12(b)(3).
In reaching this conclusion, we find unpersuasive defendant’s assertion that the decision
in People v. Saunders, 261 Ill. App. 3d 700 (1994), establishes that Rule 12 is controlling only
when the issue is whether a party to a proceeding was properly served. The issue in Saunders
was whether the defendant timely filed his postconviction petition, and the State argued that
under Rule 12(c), defendant’s petition was not filed until four days after the date of mailing that
was reflected in the defendant’s notarized proof of service. The court noted that Rule 12(c) states
that service by mail is complete four days after mailing and that the committee comments to Rule
12 state that subsection (c) was added to establish, when service is made by mail, a definite
starting point for measuring the time periods that begin to run on the date of service, such as in
Rule 213(c). Saunders, 261 Ill. App. 3d at 705. The court further noted, by way of example, that
Rule 213(c) states that a party must serve answers and objections to interrogatories within 28
days of the date that the interrogatories were served upon him, and the court thus held that Rule
12(c) applies only when the date of service is relevant to the determination of when a particular
time period commences. Saunders, 261 Ill. App. 3d at 705. We express no opinion as to the
court’s interpretation of Rule 12(c), and instead find it sufficient in this case to point out that the
