[brief] COUNTERSTATEMENT OF PROCEDURAL HISTORY AND FACTS  For purposes of this brief, the State will rely upon and incorporate by reference the procedural history and facts delineated in the Appellate Division’s unpublished opinion of the defendant’s direct appeal of his third petition for post-conviction relief.  See (Pa1-6).  On March 1, 2007, a Middlesex County grand jury returned [...] ("[...]"), charging defendant with two counts of third-degree aggravated assault on a police officer, contrary to N.J.S.A. 2C:12-1(b)(5)(a), one count of third-degree resisting arrest, contrary to N.J.S.A. 2C:29-2(a)(3)(a), and one count of fourth-degree obstructing the administration of law or other government function, contrary to N.J.S.A. 2C:29-1(b).  On March 22, 2007, a Middlesex County grand jury returned [...] ("[...]"), charging defendant with one count of third-degree eluding, contrary to N.J.S.A. 2C:29-2(b).  On January 22, 2008, a Middlesex County grand jury returned [...] ("[...]"), charging defendant with two counts of third-degree distribution of cocaine, contrary to N.J.S.A. 2C:35-5(a)(1) and N.J.S.A. 2C:35-5(b)(3), one count of third-degree possession of phencyclidine ("PCP"), contrary to N.J.S.A. 2C:35-10(a)(1), one count of third-degree forgery, contrary to N.J.S.A. 2C:21-1(a)(2), and one count of fourth-degree theft or unlawful receipt of a credit card, contrary to N.J.S.A. 2C:21-6(c).  Finally, on September 11, 2009, a Middlesex County grand jury returned [...] ("[...]"), charging defendant with one count of second-degree distribution of cocaine within 500 feet of a public park, contrary to N.J.S.A. 2C:35-5(a) and N.J.S.A. 2C:35-7.1, third-degree possession of cocaine, contrary to N.J.S.A. 2C:35-10(a)(1), third-degree possession of cocaine with intent to distribute, contrary to N.J.S.A. 2C:35-5(a)(1) and N.J.S.A. 2C:35-5(b)(3), and one count of fourth-degree tampering with evidence, contrary to N.J.S.A. 2C:28-6(1).  On March 16, 2010, defendant entered into a negotiated global plea agreement, resolving all charges reflected in the four indictments.  Through this agreement, defendant pled guilty to one count of third-degree distribution of cocaine under [...], one count of third-degree possession of cocaine with intent to distribute under [...], fourth-degree obstructing the administration of law under [...], and third-degree eluding under [...].  On December 8, 2010, consistent with the plea agreement, defendant was sentenced to an aggregate term of ten years' imprisonment, with five years of parole ineligibility.  Defendant has attempted to reverse his conviction or withdraw his plea seven times.  On June 22, 2010, defendant submitted a certification in support of his application to withdraw his guilty plea, which was denied on July 2, 2010.  On direct appeal, defendant argued that the court erred in denying his application to withdraw his guilty plea.  On June 21, 2013, we rejected defendant's argument and affirmed.  State v. [...], [...] (App. Div. June 21, 2013) (slip op. at 1).  On January 17, 2012, defendant filed his first PCR application self represented, claiming that he was "tricked" by plea counsel into accepting the plea deal.