Case 1 :07-po-00001-IVIPT Document 3 Filed 01/16/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, )
v. I Criminal Action No. 07- ff) - AA
FERNANDO ROMERO-FONSECA, I
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. § 3 142(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):
__ Crime ofviolence (18 U.S.C. § 3156)
1 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
QL Serious risk defendant will flee
_ Serious risk obstruction ofjustice
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both): __M__
i Defendants appearance as required ll I l— E D l
_ Safety of any other person and the community 1 I , _1
I l ·.lnl\: l c-
i
l .Z:i`EC·um l
l .
Case 1:07-po—OOOO1-|\/IPT Document 3 Filed O1/16/2007 Page 2 of 3
3. Rebuttable Presumption, The United States WILL NOT invoke the
rebuttable presumption against defendant under § 3142(e). (If 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,
_ At first appearance
L After continuance of _; 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):
l. 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 1:07-po—OOOO1-l\/IPT Document 3 Filed O1/16/2007 Page 3 of 3
6. Other Matters.
DATED this 16th day of January , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
5/9;%;/ Z
BY: 4 L / » · -
Robeit F. Kravetz i
Assistant United States · orney