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

" , » Case 1 :08-mj-00100-UNA Document 3 Filed 06/06/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, g
v. ) Criminal Action No. 08- 0
FELIPE PABLO-JIMENEZ, % AA
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. § 3142(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 of violence (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 or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
n L Serious risk defendant will flee
_ 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):
A Defendant's appearance as required
_ Safety of any other person and the community
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): U
__ Probable cause to believe defendant cormnitted 10+ year drug offense or
F | |_ E Dfirearm offense, 18 U.S.C. § 924(c)
Pre ious conviction for "eligible" offense cormnitted while on pretrial bond
JUN 0 2008
Dl§?i?é?l§l'%'rEE£§lE

Case 1:08-mj—00100-UNA Document 3 Filed 06/06/2008 Page 2 of 2
4. Time For Detention Hearing. The United States requests the court conduct the
detention hearing,
_ At first appearance
_ 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 l0 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.
L 2. The defendant is not a citizen of the U.S. or lawfully admitted for pennanent
residence.
_)j____ 3. The defendant may flee or pose a danger to any other person or the community.
DATED this 6th day of June , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: %
ana H. Eisenstein
Assistant United States Attomey

Case 1:08-mj-00100-UNA

Document 3

Filed 06/06/2008

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Case 1:08-mj-00100-UNA

Document 3

Filed 06/06/2008

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