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

Case 1 :07-cr-00114-JJF Document 4 Filed 08/13/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff g
v. g Criminal Action No, 07-
‘ MATIMA MILLER, i
Defendant. 3
MOTION FOR DET ENT ION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3142(e) and (t). In support of the 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)
__ Maximum sentence life imprisonment or death
__ 10+ year drug offense
_ Felony, with two prior convictions in above categories I
_ Minor victim
_X_ Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
é Serious risk defendant will flee
1 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):
A Defendant's appearance as required F I [_ E D
A Safety of any other person and the community
AUG 1 -. ge.;/J?
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Case 1:07-cr-00114-JJF Document 4 Filed 08/13/2007 Page 2 of 3
3. Rebuttable Presumption. The United States will not invoke the rebuttable
presumption against defendant under § 3142(e). (If yes) 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), 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,
_ At first appearance
_ A After continuance of L days (not more than 3).
5. Temporary Detention. The United States requests 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 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-cr—00114-JJF Document 4 Filed 08/13/2007 Page 3 of 3
DATED this 13th day 0f August, 2007.
Respectfully submitted,
CO OLLY
Uni ttomey ·
Iii ll:
l
Sha
Ass States Attomey

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