CASE:

CASE:

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

• Motion to enforce plea agreement
• Notice of motion to enforce plea agreement