Case 1 :07-cr-00012-GIVIS Document 4 Filed 01/11/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ‘ )
Plaintiff, i
v. i Criminal Action No. 07-04-M p
J ORGE MEJIAS, i
Defendant. i 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 ofthe motion, the United States alleges the
following:
1. Eligibilitv of Case. This case is eligible for a detention order because case
involves (check all that apply):
2 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
_i{_ 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):
L -.·- ...._ . Y. .,. ....., __,._` .,.. . ...,... ....i....r.~ ...r .~ -·—~-
__ Safety of any other person and the community n ·· -
E iliillli 11 mi
i i
...... . 3 ,....
Case 1 :07-cr-00012—GIV|S Document 4 Filed 01/11/2007 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 Hearing. The United States requests the court conduct
the detention hearing, h
__ At first appearance
__ 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 connnitted 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 1:07-cr-00012-GIVIS Document 4 Filed O1/11/2007 Page 3 of 3
6. Other Matters.
DATED this 11th day of J anuagg , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: F ~ »< ./ it ‘/C A Q LM ’
Beth MoskoW—Sehnoll 0
Assistant United States Attorney