prosecutor’s comments about Urista effectively undermined the sentencing recommendation. ... Though [the prosecutor] made the sentencing recommendation, her additional comments at sentencing indicate that she merely paid lip service to the recommendation."); State v. Rardon, 313 Mont. 321, 61 P.3d 132, 136 (2002) ("While we agree it is completely appropriate for the prosecutor to question victims and solicit their testimony at a sentencing hearing and for those victims to express their fears and feelings, it is not acceptable for a prosecutor to aggressively solicit testimony that is clearly intended to undermine the plea agreement and to convince the sentencing court that a plea bargained sentence should not be accepted."); State v. Landera, 285 Neb. 243, 826 N.W.2d 570, 576 (2013) (<HOLDING>); Vanden Hoek v. Weber, 724 N.W.2d 858, 862-63
holding that a merger clause normally prevents a criminal defendant who has entered into a plea agreement from asserting that the government made oral promises to him not contained in the plea agreement itself holding that promises made in a plea agreement could violate 18 usc  201c holding a party breaches a plea agreement by acting in a manner not specifically prohibited by the agreement but still incompatible with explicit promises made in the agreement holding that where one party had received a written agreement and conformed his conduct to that agreement for an extended period of time but failed to sign the agreement he was equitably estopped from denying the validity of the agreement holding that proof of an explicit agreement is not required