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

Case 1 :07-cr-00077-SLR Document 9 Filed 08/O2/2007 Page 1 of 2
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U IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ) I I _
)
v. ) _ _
) Crim1nalAct1on N0. 07-77-SLR
CLARENCE LEWIS, _ g
I Defendant. )
. · MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant, 3
pursuant to 18 U.S.C. § 3 142(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):
_____ Crime ofviolence (18 U.S.C. § 3156) .
_ 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 A
X Serious risk defendant will flee
Serious risk obstruction of justice _
2. Reason For Detention. The coun; should detain defendant because there are no
conditions of release which will reasonably assure (check one or both):
n X Defendants appearance as required
____}_Q__ Safety of any other person and the community ,
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W ‘ Case 1:07-cr-00077-SLR Document 9 Filed 08/O2/2007 Page 2 of 2
3. Rebuttable Presumption. The presumption applies because (check one or both): q
__ 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
I _l(__ After continuance of j___ days (not more than 3).
5. Temporaq 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):
l. At the time the offense was conunitted the defendant was:
__ (a) on release pending trial for a felony;
__ (b) on release pending imposition or execution of sentence, appeal I A
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 UQS. or lawfully admitted for permanent
residence.
____ 3. The defendant may flee or pose a danger to any other person or the community.
DATED this 2nd day of August ifn I J
Respectfully
P coLM F. CONNOLLY A "
United States Attorney ` .
na H. Eisenstein
Assistant United States Attorney