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

Case 1 :07-cr-00073-SLR Document 9 Filed 06/28/2007 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. 1 Criminal Action No. 07-73-SLR
CHRISTOPHER WATERMAN, 3
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 (t). In support ofthe motion, the United States alleges the
n following:
1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply):
__ Crime ofviolence (18 U.S.C. § 3156)
_ Maximum sentence life imprisonment or death
L 10+ year drug offense
_ Felony, with two prior convictions in above categories
_ Minor victim
_X_ 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 if released from all custody
__ 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):
L Defendant's appearance as required
i(__ Safety of any other person and the community

.V y Case 1 :07-cr-00073-SLR Document 9 Filed 06/28/2007 Page 2 of 3
3. Rebuttable Presumption. The United States will invoke the rebuttable
presumption against defendant under § 3 l42(e). (Ifyes) The presumption applies because
(check one or both):
QL 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 ( ) 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
- _; 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 (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-cr-00073-SLR Document 9 Filed 06/28/2007 Page 3 of 3
_ 6. Other Matters.
DATED this 28th day of June, 2007.
_ _ Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY;
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S-peciai Assistant United States Attorney