OPINION
SCHROEDER, Circuit Judge:
Dzung Ahn Pham, formerly a licensed physician, seeks to withdraw his guilty plea to conspiracy to distribute controlled substances in violation of the Controlled Substances Act (CSA), 21 U.S.C. § 846. The Act criminalizes the distribution of narcotics "[e]xcept as authorized." 21 U.S.C. § 841...
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