IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE 1
UNITED STATES OF AMERICA, )
Plaintiff, g 2
v. g Criminal Action No. 06-143-UNA
GREGORY CARTER, g . I
Defendant. g
MOTION FOR DETENTION HEARING i
l
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3l42(e) and (f). In support of the motion, the United States alleges the
following: i
1. Eligibility of Case. This case is eligible for a detention order because case I
involves (check all that apply): B “+ g
__ Crime ofviolence (18 U.S.C. § 3156) _ i /
______ Maximum sentence life imprisomnent or death l 6 EQU? i I
__;(_ 10+ year drug offense USA Dj§{,;,]
__X_ Felony, with two prior convictions in above categori€sâ€"""`I`2§“l;liilEET{2§
_____ Minor victim
i Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
A Serious risk defendant will flee l
__ 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 Defendants appearance as required
A Safety of any other person and the community
I 1 S Case 1 :06-cr-00143-GMS Document 12 Filed 08/16/2007 Page 2 of 3
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):
_g(____ 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 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
L After continuance of j_____ 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 I
be notified since (check 1 or 2, and 3): .
1. At the time the offense was committed the defendant was: E
_ (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 1:06-cr-00143—G|\/IS Document 12 Filed 08/16/2007 Page 3 of 3
6. Other Matters.
DATED this 16* day of August 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney -
BY: _ . . »·.·‘
Robert F. Kravetz
Assistant United States •· y