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

I Case 1 :07-cr-00070-JJF Document 7 Filed 06/27/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
g _ FOR THE DISTRICT OF DELAWARE -
I - UNITED STATES OF AMERICA, ‘ : _
Pnimiri; S I
; v. Criminal Action No. 07-70 JIF
I y DANIEL JoHNsoN, E p .
U Defendant. p
I - MOTION FOR DETENTION HEARING `
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3 142(e) and (i). In support ofthe motion, the United States alleges the
I following:
1. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply): I
I __ Crime ofviolence (18 U.S.C. § 3156) . I
___ Maximum sentence life imprisonment or death
I A 10+ year drug offense I
____ Felony, with two prior convictions in above categories U
I I ‘ _ Minor victim II I
_ Possession! use of firearm, destructive device or other dangerous weapon I I
_; Failure to register under 18 U.S.C. § 2250 ` c
A Serious risk defendant will flee I E.
_ Serious risk obstruction of justice I V
2. Reason For Detention. The court should detain defendant because there me
no conditions of release which will reasonably assure (check one or both):
QL Defendant's appearance as required p
J(___ Safety of any other person and the community

Case 1 :07-cr-00070-JJF Document 7 Filed 06/27/2007 Page 2 of 3
3. Rebuttable Presumption. The United States will/will not invoke the
_ rebuttable presumption against defendant tmder § 3142(e). (If yes) The presumption applies
because (check one or both):
‘ L Probable cause to believe defendant committed 10+ year drug offense or A i
q firearms offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified
· offense ( ) with minor victim
I _ 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, l
U _; At first appearance
A After continuance of __; days (not more than 3).
-‘ 5. Temporary Detention. The United States request the temporary detention of
I 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: _
1 (a) on release pending trial for a felony;
____ (b) on release pending imposition or execution of sentence, appeal ·
I of sentence or conviction, or completion of sentence for an offense;
_ (c) on probation or parole for an offense. A
_____ 2. The defendant is not a citizen of the U.S. or lawfully admitted for permanent n
residence. _
____ 3. The defendant may flee or pose a danger to any other person or the community.
I

Case 1 :07-or-00070-JJF Document 7 Filed 06/27/2007 Page 3 of 3
6. Other Matters.
DATED this 27th day of June, 2007.
S an Respectfully submitted,
._ COLM F. CONNOLLY
s United States Attorney
A BY; { · /{/{·»C....l-» . `
Douglas . McCann —
Assist United States Attorney