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, )
)
v. )
) Criminal Action N0- 07—86
ARMANDO SAUCEDO—LOZANO, )
aka Thomas Estuopina )
)
Defendant )
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. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply):
Crime ofviolence (18 U.S.C. § 3156)
1 Maximum sentence life imprisonment or death
10+ year drug offense
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
2. Reason For Detention. The court should detain defendant because there are no
conditions of release which will reasonably assure (check one or both):
X Defendant‘s appearance as required
Safety of any other person and the community

, » Case 1 :07-cr-00086—GIV|S Document 5 Filed 06/28/2007 Page 2 of 2
3. Rebuttable Presumption. The United States WILL NOT invoke the rebuttable
presumption against defendant under § 3142(e). (lf yes) The presumption applies because .
(check one or both):
__ Probable cause to believe defendant committed 10+ year drug offense or
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
X After continuance of 3 days (not more than 3).
5. Temporag 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 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.
_ DATED this 28th day of June , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
_ _ ana H. Eisenstein
Assistant United States Attorney