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Motion to Compel and Enforce Agreement (Steve Nodine Case)

Motion to Compel and Enforce Agreement (Steve Nodine Case)

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Published by WKRGTV

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Published by: WKRGTV on Oct 26, 2011
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10/26/2011

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IN THE CIRCUIT COURT OF BALDWIN COUNTY, ALABAMASTATE OF ALABAMA, ))Plaintiff, ))vs. ) CC-10- 1745)Stephen Nodine )
Judge Partin
 )Defendant )MOTION TO COMPEL THE STATE OF ALABAMA TO NOLLE PROSEQUI AND TOENFORCE THEIR AGREEMENT WITH THE DEFENSEComes now the Defendant and does hereby move this Honorable Court to Compelthe State of Alabama to nolle prosequi the remaining counts of the indictment and to enforcethe agreement made with the defense in the above-referenced case based upon thefollowing:1.
 
The State of Alabama has made numerous promises to counsel for the Defendantthat this case was to be nolle prosequi based on the superseding indictment thatwas returned in CC-11-1635 wherein the Defendant was charged with CriminallyNegligent Homicide (and Perjury).2.
 
In reliance on these promises the Defense has honored a request from the State of Alabama asking the Defense to forebear filing its own motion to dismiss untilsuch time as the State could file its own detailed motion to dismiss.3.
 
The State has blatantly reneged on this promise to the detriment of theDefendant.4.
 
This motion is made under the authority of Ex Parte Yarber, 437 So. 2d 1330(Ala. 1983).
 
WHEREFORE, the Defendant requests this court to schedule an evidentiary hearing and toreceive testimony in support of this motion.DONE: October 24, 2011 /s/ John W. Beck JOHN W. BECKAttorney for Defendant(BEC021)BECKDEFENSE.COM, INC.Post Office Box 931Fairhope, Alabama 36533(251) 990-5454 Office(251) 990-5410 FacsimileEmail: john@beckdefense.com CERTIFICATE OF SERVICEI do hereby certify that on October 24, 2011 a copy of the foregoing pleading wasautomatically served on opposing counsel for the State of Alabama through the Alafilesystem. /s/ John W. Beck JOHN W. BECKAttorney at Law

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