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

Case 1:06-mj-000;*%.It/Illgill HQO(iCl:1iIB%H1 fhmulfxiled E_.l?age 1 of 2
n IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff
v. Criminal Complaint No. 06-18-MPT
ARTEMIO DIAS-BRAVO,
Defendant.
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 l42(e) and (i). In support of the motion, the United States
alleges the following:
1. Eligibility of Case. This case is eligible for a detention order because the 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
L Serious risk defendant will flee
__ Serious risk obstruction ofjustice
2. Reason For Detention. The court should detain defendant because there are
no conditions ofrelease which will reasonably assure (check one or both):
i(__ Defendant's appearance as required
__ Safety of any other person and the community

Case 1:O6—mj-OO018—lV|PT Document 4 Filed O2/O3/2006 Page 2 of 2
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
X After continuance of 3 days (not more than 3).
DATED this if day of February, 2006.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
By: 1 . "_»Ar___ i · -2,.
Adam Safwat J
Assistant United States Attorney