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

Case 1 :07-cr-00145-GIVIS Document 35 Filed 06/23/2008 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff,
v. Criminal Action No. 07-145-GMS
JOAN SANTIAGO ,
Defendant.
MOTION FOR DETENTION
NOW COMES the United States and moves for the detention of the defendant,
JOAN SANTIAGO, pursuant to 18 U.S.C. §§ 3l43(a) & 3 148(b) and Federal Rules of Criminal
Procedure 32.l(a)(6) and 46(d), pending a hearing on the violation of release petition. In support
of the motion, the United States alleges as follows: (a) there is probable cause to believe that the
defendant has committed a Federal, State, or local crime while on release; (b) there is probable
cause to believe that the defendant has violated one or more conditions of his release; (c) that,
based on the factors set forth in 18 U.S.C. § 3 l42(g), there is no condition or combination of
conditions of release that will assure that the defendant will not flee or pose a danger to the safety
of any other person or the community; and (d) that the defendant is unlikely to abide by any
condition or combination of conditions of release.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
By: F lj %
Seth M. Beausang
Assistant United States Attorney
Dated: June 23, 2008.

Case 1:07-cr-00145-GMS

Document 35

Filed 06/23/2008

Page 1 of 1