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

Case 1 :07-mj-00063-lVI PT Document 3 Filed O4/O4/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
l Plaintiff, i l l
_ v. g Criminal Action No. 07- b’§;v\,.l,,`p.I»·
PASAHA SANDS, ) U
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 (f). In support of the motion, the United States alleges the
following: . ‘
1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply): U ‘
_ Crime ofviolence (18 U.S.C. § 3156) U
_ Maximum sentence life imprisonment or death
· _ 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 `
% Serious risk defendant will flee .
____ U Serious risk obstruction of justice
12. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both):
; Defendant's appearance as required an U ni-. _ 1
A Safety of any other person and the community I _ U l
.—.¤ `.i · --1 .

Case 1:O7—mj-OO063—IV|PT Document 3 Filed O4/O4/2007 Page 2 of 3
3. Rebuttable Presumption. The United States WILL NOT invoke the
` rebuttable presumption against defendant under § 3142(e). (If yes) The presumption applies I V
because (check one or both): A
__ Probable cause to believe defendant committed 10+ year drug offense or -
l firearms offense, 18 U.Si.C. § 924(c), or a federal crime of terrorism, or a specified
offense 1 ) with minor victim l
_ Previous conviction for "eligible" offense committed while on pretrial bond l
. 4. Time For Detention Hearing. The United States requests the court conduct i
the detention hearing,
+ At first appearance
_j(__ After continuance of _3__ 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):
T 1. At the time the offense was committed the defendant was:
+ (a) on release pending trial for a felony; _
l _ (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. .
1 __ 3. The defendant may flee or pose a danger to any other person or the community.

Case 1 :07-mj—OOO63-MPT Document 3 Filed O4/O4/2007 Page 3 of 3 _
6. Other Matters. ·
A DATED this Li fh day of g , 200l.
i Respeotilly submitted,
COLM CONNOLLY
_ United tes Attorney
/ , /
BY: -'=‘ AIAAM . · 4MnA( ~
Christo .Burke
~ ASSiSt8.I§UHi’[€d StatesAttomey