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

C} L Case 1:07-mj-00074-IVIPT Document 4 Filed 04/19/2007 Page 1 of 3
1N THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff] g
v. i Criminal Action No. 07- /l/\
AMPARO VEGA-CORTEZ, g
Defendant. 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. § 3l42(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 of violence (18 U.S.C. § 3156)
_ Maximum sentence life iruprisonrnent or death
_ 10+ year drug offense
__ Felony, with two prior convictions in above categories
a+ Minor victim
_ Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
i__ Serious risk defendant will flee ,
__ Serious risk obstruction of justice F I i
_____g_t,t§g;_F§§§§Q%lE1’l»“Ji£¤

L Case 1:07-mj-00074-IVIPT Document 4 Filed 04/19/2007 Page 2 of 3
2. Reason For Detention. The co1n·t should detain defendant because there are no
conditions of release which will reasonably assure (check one or both):
__; Defendant's appearance as required
__ Safety of any other person and the community
3. Rebuttable Presumption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3 l42(e). (If yes) The presumption applies because (check
one or both):
_ Probable cause to believe defendant committed lO+ year drug offense or
firearms offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a
specified offense t J 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
L After continuance of L days (not more than 3).
5. Temporary 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.
A 2. The defendant is not a citizen of the U.S. or lawfully admitted for
permanent residence.
L 3. The defendant may flee or pose a danger to any other person or the
community.

_; 5 Case 1 :07-mj—00074—MPT Document 4 Filed O4/19/2007 Page 3 of 3
6. Other Matters.
DATED this [ Q day of &@·L-— ,2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
| I, r ‘*
9
By I mQQ 3’
Davi . Hall
Assistant United States Attorney