Motion to Enforce Plea AgreementState v. John Doe 

Your supervising attorney has advised you that John Doe 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. Your attorney wants to file a motion to enforce plea agreement and asks you to prepare the motion. Remember, that you are filing this motion on behalf of the defendant. In addition, prepare the following using the templates provided:

• Notice of motion to enforce plea agreement
• Affidavit
• Certification
• Proposed form of order
• Proof of mailing

MOTION TO SUPPRESS EVIDENCE

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA

State

V.

Civil Action No. 1:10BH74 (GBL/TRJ)

John Doe

Defendant

DEFENDANT’S MOTION TO SUPPRESS DEFENDANT’S MOTION TO ENFORCE PLEA BARGAIN

It comes to the consideration with the petitioner of the Case State V John Doe that the plea the bargain would be made among the parties, on the ground of the deal which was a break among both parties regarding some relaxation to the defendant upon the offering of certain acts or the payment to the prosecutor on behalf of the state.

The real scenario is about the defendant John Doe who was accessed by the prosecutor regarding the child abuse committed against the young female child, for which he was caught and got raided in his garage without the search warrant by the police. The appeal for the search without the warrant is in the process as well, which states that the drugs which were found in the garage of John Doe didn’t belong to him, he has no intentions or knowledge regarding the existence of the drugs or such kind of the substance in his possession.

Another violation during the raid was the authorization by the court, the police were not having the search warrants of the property on which they have searched and found substance. The substances also didn’t belong to the defendant, as according to the defendant, the substances were placed by someone to make a plot against him. In duration of the appealing for the suppression of the pieces of evidence found against the defendant, the deal was made between the defendant and the prosecutor to make some concession in the punishment of the defendant upon the acceptance of the crime or paying some amount in exchange.

Initially the deal was supposed to be made right after the 2 weeks of the consideration, but after a week the prosecutor change his stance and went back to the option of the aggression against the defendant through the providence of the proofs. Such a condition has worried the defendant as the consideration was made earlier about the plea bargain between the defendant and the prosecutor.

The plea bargain which was considered between the both of the parties was the payment of the $100000 on the second date of the month of July. This would have given the concession to the defendant on the payment of the lumpsum amount. But in the month of the February, the prosecutor turns down the deal and kept to his earlier stance.

Therefore, on this ground, the defendant requests the District court of New York to renege on its covenant. Further, the defendant appeals that his plea must be presented in accordance with the terms considered earlier.

Respectfully submitted,

BY: __________________________

Name

State Bar No. [BAR NUMBER]

Address

City, State, Zip

Telephone

THE STATE OF NEW JERSEY

Alexandria Division

State

V

John Doe

BRIEF IN SUPPORT OF DEFENDANT’S MOTION

TO ENFORCE PLEA BARGAIN

COMES NOW the Defendant, and in support of his Motion to Enforce Plea Bargain, would show the Court that:

STATEMENT OF THE FACTS

As the defendant accepted the plea bargain in the good faith that would oblige the state and would benefit the defendant as well. The failure lies with the prosecutor due to the failure of reaching to the point of the agreement between both parties. the defendant requests the relocation of the agreement about the plea bargain with the prosecutor.

ARGUMENT

The plea bargain is the assurance that the criminal cases must be solved with the finality. The plea bargain serves the best interest to the both of the parties through the making of the right lawful deal.

CERTIFICATE OF SERVICE

I Alfred Simons hereby certify that on behalf of John Doe [Defendant] a copy of the foregoing motion was hand delivered to the United States Attorney’s office to the clerk.

Robert W. Story

Nevada

Defendant-Appellant