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Case: 25CO1:17-cr-00601-WLS Document #: 5 Filed: 02/02/2018 Page 1 of 3

IN THE COUNTY COURT OF THE FIRST JUDICIAL DISTRICT OF

HINDS COUNTY, MISSISSIPPI

STATE OF MISSISSIPPI/COUNTY OF HINDS

vs. CASE NO. 17-601

JUSHUN PAIGE DEFENDANT

MOTION TO SET BOND

COMES NOW, Jus hun Paige (Paige) , by and through undersigned counsel,

and files this his Motion to Set Bond, and in support hereof would show unto

this Court the following, to-wit:

1.

Paige was arrested on or about October 24, 2017 and charged with

accessory after the fact to murder.

2.

From and since that date Paige has been detained in the Hinds County

Detention Center in Raymond, Mississippi.

3.

A preliminary hearing was held in this matter on November 13, 2017 and

the Court did not set a bond for Paige based on a representation by the

Jackson Police Department (JPD) officer who testified at the preliminary

hearing that Hinds County, Mississippi had a hold on Paige.

4.

There was not a hold pending against Paige on that date as verified by

the Court Administrator.

5.

The Court then stated it would reconsider a bond after seven (7) days

if there was in fact no pending hold.

6.

On December 18, 2017, five (5) weeks after the preliminary hearing,

Paige again appeared before the Court to request a bond.

..
Case: 25CO1:17-cr-00601-WLS Document #: 5 Filed: 02/02/2018 Page 2 of 3

7.

An Assistant District Attorney (ADA) then represented to the Court that

the State would indict Paige on or by January 8, 2018.

8.

The Court again said it would reconsider a bond in the event Paige was

not indicted per the ADA's statement.

9.

Notably, the release of Nicholas Coates (Coates), the driver of the

vehicle involved in the shooting/murder, was secured from the Detention

Center on or about January 10, 2018 without Coates having to post a bond and

without him being indicted.

10.

According to the JPD officer who testified at the preliminary hearing,

it was Coates who allegedly implicated Paige in the shooting/murder. Coates

is now free having posted no bond and Paige is still detained without bond.

12.

Another five (5) weeks have passed since January 8th and Paige has not

been indicted and there is still no hold against him by any agency as of the

date of filing this Motion.

13.

At the time of his arrest in October 2017, Paige was gainfully employed

with Kentucky Fried Chicken as a crew manager and had been so employed for

several months.

14.

Paige does not pose a flight risk, his release does not constitute a

special danger to the community, and his appearance before this Court post-

release from detention is assured.

 Case: 25CO1:17-cr-00601-WLS Document #: 5 Filed: 02/02/2018 Page 3 of 3

15.

Based on the above and foregoing, Paige respectfully requests that this

Court set bond in a reasonable amount given the facts and circumstances that

gave rise to his arrest.

WHEREFORE PREMISES CONSIDERED, Paige respectfully prays that after a

hearing on this his Motion to Set Bond, this Honorable Court will enter an

Order setting bond in a reasonable amount. Paige further prays for such other

and further relief as this Court may deem just and proper under the premises.

RESPECTFULLY SUBMITTED this the 1st day of February, 2018.

Is/Rhonda C. Cooper
MID-TOWN LAW OFFICE, P.A.
POST OFFICE BOX 11556
JACKSON, MISSISSIPPI 39283
( 601) 354-2594
RHONDA C. COOPER
MSB NO. 6511
ATTORNEY FOR JUSHUN PAIGE

CERTIFICATE OF SERVICE

I, RHONDA C. COOPER, do hereby certify that I have this day caused to

be delivered, via electronic mail, a true and correct copy of the above and

foregoing Motion to:

Honorable Tomie T. Green

District Seven Circuit Judge
c/o Frances Ashley, Court Administrator
Hinds County Circuit Courthouse
Jackson, Mississippi 39201

Pat McNamara, Esq.

District Seven Assistant District Attorney
Hinds County District Attorney's Office
Jackson, Mississippi 39201

SO CERTIFIED, this the 1st day of February, 2018.

Is/Rhonda C. Cooper
RHONDA C. COOPER
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Case: 25CO1:17-cr-00601-WLS Document #: 2 Filed: 10/31/2017 Page 1 of 1

IN THE COUNTY COURT OF HINDS COUNTY, MISSISSIPPI 11 I AO (

FIRST JUDICIAL DISTRICT J. I ""' lP

STATE OF MISSISSIPPI PLAINTIFF

vs. NO: 201 7-134070B

JUSHUN PAIGE DEFENDANT

ORDER ALLOWING COUNSEL TO WITHDRAW

AND SUBSTITUTE COUNSEL

This cause having come before the Court on Motion ore tenus of the Defendant,
by and through the Hinds County Public Defender, requesting the Court to allow the
Hinds County Public Defender to withdraw as attorney of record tor the Defendant due to
a conflict of interest, as the Public Defender represents co-defendant Lidarius Dixon, and
the Court being advised in the premises finds that the Order should be granted;
IT IS NOW ORDERED that the Hinds County Public Defender is hereby
withdrawn as attorney of record for the Defendant, and the Court appoints the Honorable
_,~
L...:>o~~·-lfm-fh"=4-"Pd~---- to be substituted as counsel for the Defendant, Jushun
Paige.
AND ADJUDGED, this the oo day of

~JUDGE
--+~-=---=::...,.,.--~-'---' 20 17.

GR ··G P; RE (MS BAR # 103764)

I'

AS . ' NT PUBLIC DEFENDER

Office ofthe Hinds County Public Defender
499 South President Street
Post Office Box 23029
Jackson, Mississippi 39225
Telephone: 601-948-2683
Facsimile: 60 l-948-2687