Paralegal to wright a motion to dismiss creminal case

I entered a contract with a gentleman I have known for over 16 years to remodel a home. Prices doubled in April 2022. He felt he was defrauded and filed a criminal case. Were as we have performed business after the filing. We our currently negotiating a larger business deal as of 13 Dec 2022. He agreed to req the courts (City of Fredericksburg VA) to dismiss the case. However we feel we should have a written motion to dismiss. The case is 29 Dec and will satisfy your invoice ASAP