Opinion
NO. 3:10-cr-00212-1
10-12-2012
UNITED STATES OF AMERICA v. PEREZ BASS
MICHAEL E. TERRY (BPRN 3856) STEPHANIE H. GORE (BPRN 17080) Counsel for Perez Bass
JUDGE NIXON
MOTION FOR CHANGE OF PLEA HEARING
Defendant, through counsel and pursuant to the Federal Rules of Criminal Procedure and applicable law, moves this Court to enter an order scheduling a change of plea hearing in this cause on a date and time convenient with the Court's docket. In support, defendant would respectfully show:
1. On August 12, 2010 defendant was charged by indictment. Defendant is indigent, and undersigned counsel has been appointed by this Court to represent him.
2. Trial is set for October 30, 2012, at 9:00 a.m. (Docket No. 58).
3. Defendant intends to enter a plea of guilty pursuant to a plea agreement, and requests that a hearing be set on a date and time convenient with the Court's docket. Defendant is incarcerated and housed in Bowling Green, Kentucky.
RESPECTFULLY SUBMITTED,
________
MICHAEL E. TERRY (BPRN 3856)
STEPHANIE H. GORE (BPRN 17080)
Counsel for Perez Bass
Terry & Gore
1200 16th Avenue, South
Nashville, TN 37212
(615) 321-2750 office
(615) 250-4915 fax