§ 8.20 1. What You Want
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To prepare for the negotiation, counsel should have an exact definition of the target disposition. See § § 5.26, 8.10, supra. In addition, s/he should be prepared with similar specific definitions of each of the back-up safe havens the client would accept if the most desirable disposition is not acceptable to the prosecution. The defense requests should concentrate on the criminal disposition of the case (and any relevant prior convictions), since it is very difficult or impossible to persuade the prosecution to make any promises as to whether the defendant will in fact be deported. See § 8.16(C), supra.