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

Case 1 :08-mj-00099 Document 2 Filed 06/O3/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
v. )
)
LLOYD L. STAFFORD, ) Criminal Action No. 08- M
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. Eligjbilig; 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 _
n _ 10+ year drug offense
_ Felony, with two prior convictions in above categories
L Minor victim, possession or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
__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):
__ Defendant‘s appearance as required

Case 1:08-mj-00099 Document 2 Filed 06/O3/2008 Page 2 of 3
_; Safety of any other person and the community
3. Rebuttable Presumption. 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
L After continuance of L days (not more than 3).
5. Temporag 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;
_ (0) on probation or parole for an offense.
_ 2. The defendant is not a citizen of the U.S. or lawfully admitted for permanent
residence.

Case 1:08-mj-00099 Document 2 Filed 06/O3/2008 Page 3 of 3
3. The defendant may flee or pose a danger to any other person or the community.
DATED this 3rd day of June , 2008.
4 Respectfully submitted,
COLM F. CONNOLLY
U ·• State-:sA • r' ey
· \
BY: QL ttl _.i_._
L 1cy F. ir
Assistant U ited States Attorney

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