United States v. Arqueta-Ramos, 730 F.3d 1133 (No. 10-10618) (9th Cir. Sept. 20, 2013) (vacating misdemeanor plea to illegal entry into the U.S., in violation of 8 U.S.C. 1325, where simultaneous plea was taken en masse by 66 defendants represented by 15 lawyers, through Operation Streamline violated Rule 11 of the Federal Rules of Criminal Procedure, because it did not meet Rule 11(b)(1)s requirement that the court address each defendant personally; the court did not engage in person to person speech during the advisement of rights or the subsequent small group questioning of the defendants.; this was prejudicial; since the defendant objected, the burden fell on the government to show she would have entered this plea if her rights had not been violated, which the government could not do). Concerning Operation Streamline, see Jennifer M. Chacn, Managing Migration Through Crime, 109 Columbia Law Review Sidebar 135 (2009).