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

Case 1 :07-mj—OO252—UNA Document 4 Filed 12/21/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, n l
v. l Criminal Action No. 07- Q $2 * M
KEVIN MASON, %
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. § 3l42(e) and (f). In support of the motion, the United States alleges the
following: U
1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply):
U L Crime ofviolence (l8 U.S.C. § 3156) _ F l E D
_________ Maximum sentence life imprisonment or death I D EC 2 1 EGG? i
L 10+ year drug offense i h—_—~_—l
L Felony, with two prior convictions in above categori E gg
L Minor victim
_ Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
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): I
L Defendants appearance as required
L Safety of any other person and the community

Case 1 :07-mj—OO252—UNA Document 4 Filed 12/21/2007 Page 2 of 3
3. Rebuttable Presumption. The United Sta ill not invoke the
rebuttable presumption against defendant under § 3 142(e). (If yes) The presumption applies
because (check one or both): 3
_j_{_ Probable cause to believe defendant committed 10+ year drug offense or
firearms 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, U
__ At first appearance
_)_L 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 l0) 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. I
___ 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 1:07-mj—OO252—UNA Document 4 Filed 12/21/2007 Page 3 of 3
6. Other Matters.
DATED this day of 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attcmey
BY; @
ebelt J. Prett an
Assistant Unite States Attomey

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