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

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IN THEUNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
_ Plaintiff, g
v. - l Criminal Action No. 07-98-UNA
CARL W. WILSON, JR., l 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. § 3 l42(e) and (f). In support of the motion, the United States alleges the
following:
_ l. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply): .___.kpp ` __:p v N l
I _)j__ Crime of violence (18 U.S.C. § 3156) if
____ Maximum sentence life imprisonment or death {im, __ 5 mm
—· ml W deg °ff“““ i
__ Felony, with two prior convictions in above catego W `_
_L_ Minor victim
___ Possession! use of firearm, destructive device or other dangerous weapon
___ Failure to register under 18 U.S.C. § 2250
__L_ Serious risk defendant will flee .
___ 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):
__;_ Defendants appearance as required
_L Safety of any other person and the community

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3. Rebuttable Presumption. The United States WILL invoke the rebuttable
presumption against defendant tmder § 3 l42(e). (If yes) The presumption applies because
(check one or both):
. _)g_ 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
p offense (violation of 18 U.S.C. § 2252Aga)(2 Q) 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
i(_ After continuance of _j_ 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 (check 1 or 2, and 3):
1. At the time the offense was committed the defendant was:
__ (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. n
___ 2. The defendant is not a citizen of the U.S. or lawfully admitted for permanent
residence.
__ 3. The defendant may flee or pose a danger to any other person or the community.

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6. Other Matters.
DATED this 5th day of July 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
. BY; · 5/w•»A<.
Christopher J. Burk
Assistant United States Attorney