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

Case 1 :07-mj-00047—IV|PT Document 3 Filed 03/12/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintifi g
v. ) Criminal Action No. O7- q -
RUDY ALVERADO, )
Defendant. )
A MOTION FOR DETENT ION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3142(e) and (i). 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! use of firearm, destructive device or other dangerous weapon
__ Failure to register under 18 U.S.C. § 2250
X Serious risk defendant will flee
_ Serious risk obstruction of justice Q_-
I"` r 2 In E 0 1
E`“Ti”m”" I
A § mlm 1 2 M i `
i MEi;li`E ii; ;1::*¤‘ in-TiiQ_ii·*—i
i . '- T-‘i.?Tf‘E£ ._,._a.,.

q Case 1:O7—mj-OO047—IV|PT Document 3 Filed O3/12/2007 Page 2 of 3
2. Reason For Detention. The court should detain defendant because there are no
conditions of release which will reasonably assure (check one or both):
X Defendant's appearance as required
_ Safety of any other person and the community
3. l Rebuttable Presumption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3142(e). (lf yes) The presumption applies because (check
one or both): t
_ 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 couit conduct the
detention hearing, 4
3 _ At first appearance
L_ - After continuance of L days (not more than 3).
1 5. Temporary Detention. The United States request the temporary detention of the
defendant for a period of [ O 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:O7—mj-OO047—lV|PT Document 3 Filed O3/12/2007 Page 3 of 3
6. Other Matters.
114;
DATED this { Z day of TV ,2007.
Respectfully submitted,
COL . CONN
G CS 1'I1
/
/6/
Edmond ow ii
Assistant Unite tates Attorney