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

p i Case 1 :07-cr-$)€'_§??g£J Ian Elziugiegggr * Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
_ - FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ) I
Plaintiff g
v. g Criminal Action No. 07- CIO ·
MIGUEL TORRES-CARRASCO, g
. 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. § 3142(e) and (f). In support of the motion, the United States alleges the
following:
1. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply): I
__ Crime ofviolence (18 U.S.C. § 3156)
___ Maximum sentence life imprisonment or death
__ 10+ year drug offense
_)L_ Felony, with two prior convictions in above categories
____ Minor victim; possession or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
_X_ Serious risk defendant will flee
- __ Serious risk obstruction of justice l
.- 2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (cheek one or both):
_)_L_ Defendants appearance as required A _ H U _ Ap H
A Safety of any other person and the community M l

Case 1 :07-cr—00090—JJF Document 7 Filed 06/27/2007 Page 2 of 3
3. Rebuttable Presumption. The United States WILL NOT invoke the
rebuttable presumption against defendant under § 3142(e). (If yes) The presumption applies
because (check one or both):
__ Probable cause to believe defendant committed 10+ year drug offense or S
firearms offense, 18 U.S.C. § 924(c) _
__ 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 _Z;_ days (not more than 3).
A 5. Temporary Detention. The United States request the temporary detention of
the defendant for a period of __ days (not more than l0) 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:
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. D
____ 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-cr—00090—JJF Document 7 Filed 06/27/2007 Page 3 of 3
6. Other Matters.
DATED this 27th day of June ‘ , 2007.
Respectfully submitted,
. COLM F. CONNOLLY
United States Attorney
BY:
R0 rt F. Kravetz
Assistant United tates ttomey .