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

Case 1 :07-mj-00031-IVIPT Document 4 Filed O2/20/2007 Eygedibf 3-} OFGJ
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintifi g ‘
v. g Criminal Action No. O7- 3 I ra`.- MW
Robert Cottman HI, g
Defendant. l
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:
l. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply): · iL·· ··
__ Crime ofviolence (18 U.S.C. § 3156)
__ Maximum sentence life imprisonment or death Q FEE Z ll QQ--...F *\
— 10+ yer deg Offense .r, 1,. als rts.
__ Felony, with two prior convictions in above categories iii- ·—--——-
__ Minor victim
_X_ Possession/ use of firearm, destructive device or other dangerous weapon
i Failure to register under 18 U.S.C. § 2250
_)_§_ Serious risk defendant will flee
__ Serious risk obstruction of justice
2. 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
A Safety of any other person and the community

Case 1:O7—mj-OO031—IV|PT Document 4 Filed O2/20/2007 Page 2 of 3
3. 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):
__ Probable cause to believe defendant committed 10+ year drug offense or
firearms offense, 18 U.S.C. § 924(c), or a federal crime ofterrorism, 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 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 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. L

Case 1:07-mj—OOO31-MPT Document 4 Filed O2/20/2007 Page 3 of 3
6. Other Matters.


DATED this 20th day of F ebgiy, 2007.
Respectftply submitted,
COLM F. CONNOLLY
United Stites Attorney
Assistant it d States Attorney