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

Case 1:O7—m`-OO043—IV|PT Document 4 Fi O /08/2 7 Page 1 of 3 "
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g OTE Li
v. g [Eastem District of Virginia
) Case No. 3:07-MJ—l32]
VVILLIAM JOHN STATTS, )
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) and Rule 5. In support ofthe motion, the United States
alleges the following:
1. Eligibility of Case. This case is eligible for a detention order because the case
involves (check all that apply):
1 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
_L Serious risk defendants will flee
_ Serious risk obstruction of justice
2. Reason For Detention. The court should detain defendants because there are
no conditions of release which will reasonably assure (check one or both):
L Defendants’ appearance as required
__ Safety of any other person and the community

Case 1:O7—mj-OO043—IV|PT Document 4 Filed O3/08/2007 Page 2 of 3
3. Rebuttable Presumption. The United States WILL NOT invoke the
rebuttable presumption against defendant under § 3142(e). (lf yes) The presumption applies
because (check one or both):
_ 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 Hearhrg. The United States requests the court conduct
the detention hearing,
_ At first appearance
A 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 l 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-OO043—lV|PT Document 4 Filed O3/08/2007 Page 3 of 3
6. Other Matters.
DATED this 8th day of March , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY; jjji C/Bj
Sophie E. Bryan
Assistant United States Attomey