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

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V . IN THE UNITED STATES DISTRICT COURT 5 6,:/
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, `
Pinutirr, i E
v. : Cr. A. No. 07- /66 fl
CHARLES A. WEBSTER,
Defendant.
MOTION 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 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
____ Minor victim
__Q(___ Possession! use of firearm, destructive device or other dangerous weapon
___ Failure to register under 18 U.S.C. § 2250 ic i i. E D
_§__ Serious risk defendant will flee ; li
(___ Serious risk obstruction of justice AUG 2 A 2007 K I

2. Reason For Detention. The court should detain defendant because there are no
conditions of release which will reasonably assure (check one or both):

Case 1:07-cr-00115-SLR Document 5 Filed 08/24/2007 Page 2 of 3
' _L_ Defendant's appearance as required
;;__ Safety of any other person and the community
3. Rebuttable Presumption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3142(e). (lf 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
V bond
4. Time For Detention Hearing. The United States requests the court conduct the
detention hearing,
___ At first appearance
__}L__ After continuance of i__ 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 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
permanent residence.
_;_ 3. The defendant may flee or pose a danger to any other person or the
community.

Case 1:07-cr-00115-SLR Document 5 Filed 08/24/2007 Page 3 of 3
6. Other Matters. -
DATED this 24th day of August, 2007. _
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney ‘
\ · Q
Bygz.-’ des /*/L CW
Dougl s . l\/[cCa11n
Assist United States Attorney

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