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

Case 1 :08-mj-00014-UNA Document 4 Filed O1/23/2008 Page 1 of 3
‘ 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
i UNITED STATES OF AMERICA, )
Plaintiff i
v. g Criminal Action No. 07- el n -
MYRON WHJLIAMS, g _
I Defendant. g
UMOTION 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 ofthe 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) 1
__ Maximum sentence life imprisornnent or death
_____ 10+ year drug offense
___ Felony, with two prior convictions in above categories
___ Minor victim
n _§_ Possession/ use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250 i
_}_(__ Serious risk defendant will flee
__ Serious risk obstruction of j ustice
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_ Defendant's appearance as required
_X_ Safety of any other person and the community

Case 1:08-mj—OOO14—UNA Document 4 Filed O1/23/2008 Page 2 of 3
' 3. Rebuttable Presumption. The United States will/will not invoke the
I rebuttable presumption against defendant under § 3 l42(e). (If yes) The presumption applies
A because (check one or both):
____ Probable cause to believe defendant committed 10+ year drug offense or
. fireanns offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified
offense ( ) with minor victim
_ 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, l
__ 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;
___ (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.

Case 1 :08-mj—OOO14—UNA Document 4 Filed O1/23/2008 Page 30f 3
F 6T Other Matters.
2

DATED this day of , 200g.
Respectfully submitted,
COLM . _ ONNOLLY
United . {gies Attorney
BY: 6
-~ . : stent United States Attomey U

Case 1:08-mj-00014-UNA

Document 4

Filed 01/23/2008

Page 1 of 3

Case 1:08-mj-00014-UNA

Document 4

Filed 01/23/2008

Page 2 of 3

Case 1:08-mj-00014-UNA

Document 4

Filed 01/23/2008

Page 3 of 3