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Case: 25CI1:17-cr-00170-JAW Document #: 15 Filed: 03/24/2017 Page 1 of 3

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI


FIRST JUDICIAL DISTRICT

STATE OF MISSISSIPPI

vs. CAUSENO. 17-170JAW

VIDAL SULLIVAN DEFENDANT

MOTION FOR BAIL REDUCTION

COMES NOW Defendant, VIDAL SULLIVAN by and through counsel of record, Frank

C. Jones, and files the instant Motion for Bail Reduction seeking relief of the setting of bail in this

cause, and as basis would show unto the Court the following, to-wit:

1. That Defendant is currently charged by indictment with commission of the felony

offenses of Armed Robbery and Felon with Firearm in this cause.

2. That Defendant has been jailed on this offense since on or about November 2016.

3. That defendant was not out on bail at the time of arrest on the instant charge.

4. That Defendant has been arraigned in the cause.

5. That Defendant would be a good risk on bond.

6. The felony offense with which Defendant is charged is a not capital offense and a

reasonable bail is merited in this cause.

7. That Defendant has been determined to be indigent by the Court.

8. That bail in this cause is presently set at $300,000.00.

9. That Defendant cannot satisfy the bail as presently set due to his lack of financial

ability.

WHEREFORE PREMISES CONSIDERED, Defendant prays that a more reasonable bail

be set in the instant cause.


Case: 25CI1:17-cr-00170-JAW Document #: 15 Filed: 03/24/2017 Page 2 of 3

RESPECTFULLY submitted this '],Lf day of t/l~Yuh '2017.

By:

OF COUNSEL:

FRANK C. JONES, III (MSB #10700)


ATTORNEY AT LAW
POST OFFICE BOX 12251
JACKSON, MS 39236
601-573-9598 tel
769-251-1448 fax
frankjones22h@comcast.net

NOTICE OF HEARING

PLEASE TAKE NOTICE that Defendant will bring the foregoing Motion on for hearing

at the Hinds County Circuit Courthouse in Jackson, Mississippi, before the Honorable Jeffrey

Weill on April _ _ _, 2017 at _ _ _ _ _.m., or as soon thereafter as counsel may be

heard.

SO NOTICED, this the 24st day of March, 2017.

FRANK C. JONES, III


Case: 25CI1:17-cr-00170-JAW Document #: 15 Filed: 03/24/2017 Page 3 of 3

CERTIFICATE OF SERVICE

I, Frank C. Jones, III, do hereby certify that I have this day delivered a true and correct
copy of the foregoing Motion for Bail Reduction to the person(s) named below by the method
named, to-wit:

Gwen Agho, Esq.


Office of the Hinds County District Attorney
Post Office Box 22747
Jackson, MS 39225-2747
601-968-6655 fax

Sent via U.S. Mail


Facsimile
~ Hand delivery

This the tJLl day of tv)gv-ch '2017.