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

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` IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE e .
UNITED STATES OF AMERICA, ) I
)
V- )
)
CHARANJIT SINGH ) Criminal Action No. 08- 25-M
K
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 (f). In support of the motion, the United States alleges the
following: l
1. Eligibility of Case. This case is eligible for a detention order because cased involves
(check all that apply):
__ Crime ofviolence (18 U.S.C. § 3156)
V Maximum sentence life imprisonment or death
___ 10+ year drug offense
Felony, with two prior convictions in above categories
Minor victim; possession or use of tirearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
X Serious risk defendant will flee X
X 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):
X Defendanfs appearance as required

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{ [ ___ 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 ding 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
‘ A After continuance of ;_ 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): p
1. At the time the offense was committed the defendant was: I
___ (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 pennanent ‘
residence.
__ 3. The defendant may flee or pose a danger to any other person or the community.

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DATED this Sth day of Februagy , 2008.
Respectfully submitted,
COLM F. CONNOLLY
Uni State mey
BY: .
L s ey .W0lf
Assistant United States Attorney

Case 1:08-mj-00025-UNA

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Case 1:08-mj-00025-UNA

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