CASE DETAILS:

i work as a paralegal for Susan H. Curcio at the law firm Smith & Smith that has its office in Hammonton, New Jersey. The firm is primarily a criminal law defense firm. It has recently been retained by Julia Doe to represent her husband, John Doe, who is incarcerated. John has been charged with a felony offense of third-degree aggravated assault. John allegedly assaulted Bob Smith in a bar for flirting with John's wife while they were sitting at the bar. The charge was initially filed in the municipal court in Hammonton and has been sent to the county because it is an indictable offense. The Indictment Number is: 05-02-00396.

My supervising attorney, Susan H. Curcio has advised me that John Doe (defendant) had initially agreed to take the plea bargain offered by the prosecutor, Gill T. Trumpo. The prosecutor has since then reviewed the decision and now would like to withdraw the plea offer. Susan wants me to file a motion to enforce plea agreement and asks me to draft the motion.

I am filing this motion on behalf of the defendant. Our case is filed in the state of New Jersey and not in Federal Court. Draft:

• Motion to enforce plea agreement
• Notice of motion to enforce plea agreement
• Proposed form of order