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

Case 1 :06-cr-00141-SLR Document 4 Filed 12/05/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OP AMERICA, )
Plaintiff, g
v. i Criminal Action No. 06- A/[ .,
JESUS SALINAS-ESCAMILLA, l `
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. § 3142(e) and (f). In support of the motion, the United States alleges the
following:
1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply):
_ 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! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
L 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 b0 . F I
L Defendants appearance as required
ii -1 \
Us rwistaici t;ui;R1
____ DISTFFCT UF 2=[L.¤.‘·*¢ARE.

Case 1:06-cr—00141-SLR Document 4 Filed 12/05/2006 Page 2 of 3
___ Safety of any other person and the community
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 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
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. U
__ 3. The defendant may flee or pose a danger to any other person or the community.

Case 1:06-cr—00141-SLR Document 4 Filed 12/05/2006 Page 3 of 3
6. Other Matters.
DATED this 5th day of December , 2006.
Respectfully submitted,
_ COLM F. CONNOLLY
United States Attorney
BY; B" ··”
l Sh on T. n n · ij.
Assistant United States Attomey