STATE OF NEW JERSEY VS. JOHN GORMAN
A-3481-16T4
After determining defendant's plea allocution did not establish a factual basis for each element of theft by deception, N.J.S.A. 2C:20-4, because defendant did not admit he deceived the victims at the time he obtained their money, the court ruled the trial judge's reliance on the theft consolidation statute, N.J.S.A. 2C:20-2(a), to accept defendant's factual basis for a different form of theft was misplaced as that statute applies only in trial settings — not to plea proceedings.
