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

Case 1 :08-cr-00105-JJF Document 6 Filed 07/22/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. l Criminal Action No. 08-105
MATTHEW MINOR, l
(a/lc/a “Mustafaa Al-Salafi;" "Staf;" "Mo"), )
Defendant. 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 (t). 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)
é Maximum sentence life imprisonment or death
i 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
A Serious risk defendant will flee
A 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):
_; Defendant's appearance as required

Case 1:08-cr-00105-JJF Document 6 Filed 07/22/2008 Page 2 of 3
A Safety of any other person and the community
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):
A Probable cause to believe defendant committed 10+ year drug offense or
firearms offense, 18 U.S.C. § 924©, or a federal crime ofterrorism, or a specified
offense ( l with minor victim
____ Previous conviction for "e1igible“ 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 __3_ 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;
_ © on probation or parole for an offense.
_ 2. The defendant is not a citizen ofthe 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 1:08-cr-00105-JJF Document 6 Filed 07/22/2008 Page 3 of 3
6. Other Matters.
DATED this 22“d day of July , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
It _ \
BY: *"""—·""" `
Q . clward J. `ndrew
/ ssistant United States Attorney

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