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

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p IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE _
UNITED STATES OF AMERICA, ) A
I Plaintiff, g `
v. - g Criminal Action N0. 07- {LY} M {W pd
I COREY ROANE, g
Defendant. g
_ MOTION FOR DETENTION HEARING
NOW COMES the United States and respectfully moves for the pretrial detention ofthe
defendant, pursuant to 18 U.SI.C. § 3 l42(e) and (t). In support of the motion, the United States
alleges the following: _
l. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply): -
_ Crime of violence (18 U.S.C. § 3156)
I _ Maximum sentence life imprisonment or death illi nlniiiii
__ 10+ year drug offense AUG II Emmy
_ Felony, with two prior convictions in above caragmiag
____ Minor victim
I __X_ Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
A Serious risk defendant will flee I
_ Serious risk obstruction of justice A . ‘
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
A Defendant's appearance as required _ e
A Safety of any other person and the community

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3. Rebuttable Presumption. The United States will not invoke the rebuttable
presumption against defendant under § 3l42(e). '(lf yes) The presumption applies because g
(check one or both): i
_ 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 i
offense { l with minor victim i- l
______ 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 l
L 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: P ‘
_ (a) on release pending trial for a felony;
_ (b) on release pending imposition or execution of sentence, appeal I
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 permanent
residence.
_ 3. The defendant may flee or pose a danger to any other person or the community.

Case 1:07-cr-00113-SLR Document 2 Filed 08/O2/2007 Page 3 of 3

6. Other Matters. _
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DATED this 2nd day of August, 2007.
n Respectfully submitted, ‘
COLM F. CONNOLLY
United States Attorney
um. |
artin Meltzer -
` Special Assistant United Sta Attorney
A t l
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Case 1:07-cr-00113-SLR

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