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

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff] l g
v. i Criminal Action No. 07- [Q5 [VI M /97,
STANLEY LUM, 3
Defendant. g
MOTION FOR DETENTION HEARING I
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3 l42(e) a.nd (fj. In support ofthe motion, the United States alleges the
following:
1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply): .....
...... Crime of violence (18 U.s,C_ § 3156)
_ Maximum sentence life imprisonment Oy death ,j<_r§g‘g“ I. 2;;
L mt Vw dwg °“°“S° ;
_ Felony, with two prior convictions in above cate :`‘ I
_____ Minor victim 0
_ X_ Possession! use of firearm, destructive device or other dangerous weapon
____ Failure to register under 18 U.S.C. § 2250
A 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):
` I A Defendant's 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 under § 3l42(e). (If yes) The presumption applies because
(check one or both):
. L Probable cause to believe defendant committed l0+ year drug offense or
firearms offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified _
offense I - ) with minor victim
·_ Previous conviction for "eligible" offense committed while on pretrial bond
4. Time For Detention Hearing. The United States requests that the Court
conduct the detention hearing,
__ At first appearance
A After continuance of L days (not more than 3).
5. Temporary Detention. The United States request 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.
_ 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.

Case 1 :07-mj—OO120—MPT Document 3 Filed 07/O2/2007 Page 3 of 3
[ 6. Other Matters.
I DATED this 2nd day of J uly, 2007.
Respectfully submitted,
I COLM F. CONNOLLY
E United States Attorney .
l
l BY:
l _ Robert J. Pre an
{ Assistant United States Attorney
l
l