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

Case 1:07-cr-00030-GIVIS Document 6 Filed O3/O2/2007 Page/Iso/F8'? ’l" 0/°"’ C"';
i ‘ 3 — ·?· 0 7 RPC;
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, - )
Plaintiff, g
I . . . y
v. ) Criminal Action No. 07- 30 ( UN R)
BRAD LEE DERRICKSON, g V
Defendant. 3 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. § 3142(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): I
X_ Crime ofviolence (18 U.S.C. § 3156) _ U
___ Maximum sentence life imprisonment or death , I
_ 10+ year drug offense
_; Felony, with two prior convictions in above categories
L Minor victim
. _ Possession/ use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250 l
x_ Serious risk defendant will flee
p _ Serious risk obstruction of justice _ li
l l`H"TTTl
j I L·l_.··1,H 2 ESQ}? l

Case 1:07-cr-00030-GIVIS Document 6 Filed O3/O2/2007 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): V
L Defendant's appearance as required -
1 A 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): ‘
X 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 ( {S C/YC 1} fl) Jvith 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, l
__ At first appearance l
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): i
_ li. at the time the offense was committed the defendant was:
l _ (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 ofthe U.S. or lawfully admitted for
permanent residence. -
S __ 3. The defendant may flee or pose a danger to any other person or the
community. U 1 _ I

. Case 1:07-cr-00030-GIVIS Document 6 Filed O3/O2/2007 Page 3 of 3
6. Other Matters.
DATED this day 0f , 2007.
Respectfully submitted,
U COLM F. CONNOLLY
United s Attom
By: Q ··
,dm0nd Falgowski
Assistant United States ‘0rney