Free Motion to Detain Pending Trial - District Court of Delaware - Delaware

Case 1 :07-cr-00095-SLR Document 6 Filed 07/O2/2007 Page 1 of 3
~ IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE (Q y
UNITED STATES OF AMERICA, ) I
Plaintiff, i ,
v. g Criminal Action No. 07-95 -UNA N
ERIC ROSS TYRE, g FILED UNDER SEAL
Defendant. g *
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3l42(e) and (D. In support of the motion, the United States alleges the ` 1
following:
1. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply):
L Crime ofviolence (18 U.S.C. § 3156)
____ Maximum sentence life imprisomnent or death
L 10+ year drug offense - °
L Felony, with two prior convictions in above categories }
L Minor victim
L Possession! use of firearm, destructive device or other dangerous weapon
L Failure to register under 18 U.S.C. § 2250 }
L Serious risk defendant will ilee U
L Serious risk obstruction of justice-
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both): I
L Defendant's appearance as required <
L Safety of any other person and the community _ _
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Case 1:07-cr-00095-SLR Document 6 Filed 07/O2/2007 Page 2 of 3
· 3. Rebuttable Presumption. The United States WILL invoke the rebuttable
presumption against defendant under § 3 l42(e). (If yes) The presumption applies because
(check one or both):
A Probable cause to believe defendant committed 10+ year drug offense or
firearms offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified
offense (violations of 18 U.S.C. §§ 2252A§a[§2)) with minor victim
__ Previous conviction for "eligible" offense committed while on pretrial bond
4. Time For Detention Hearing. The United States requests the court conduct
the detention hearing,
_ At first appearance
_)L After continuance of L days (not more than 3).
5. Temporary Detention. The United States requests the temporary detention of
the defendant for a period of _days (not more than 10) so that the appropriate officials can
be notified since (cheek 1 or 2, and 3):
1. At the time the offense was committed the defendant was: i
· ‘ _____ (a) on release pending trial for a felony;
_ (b) on release pending imposition or execution of sentence, appeal
of sentence or conviction, or completion of sentence for an offense;
_ (c) on probation or parole for an offense. . I
; 2. The defendant is not a citizen ofthe U.S. or lawfully admitted for permanent
residence. _
___ 3. The defendant may flee or pose a danger to any other person or the community.

Case 1:07-cr-00095-SLR Document 6 Filed 07/O2/2007 Page 3 of 3 I
* 6. Other Matters.
DATED this 2nd day of Jul 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney F
y BY: 5%%**
Christopher J. Bur ·
Assistant United States Attomey 4
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