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

Case 1 :07-mj—001 42-M PT Document 3 Filed 08/06/2007 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, J )
Plaintiff] g _ .
v. ‘ g Criminal Action No. 07- / M (/P//0 lj I.
I ANIE REYES—I\/IARINO , g I 1
Defendant. g ‘ l
l
MOTION FOR DET ENTION 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: Q
1. Eligibilig 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)
____ Maximum sentence life imprisornnent or death
___ 10+ year drug offense
_____ Felony, with two prior convictions in above categories
____ Mirror victim _
____ Possession! use of firearm, destructive device or other dangerous weapon
____ Failure to register under 18 U.S.C. § 2250 W W ‘
__;:__ Serious risk defendant will flee U niinl
____;_ Serious risk obstruction of justice hnlii E
[ik AUG - 5 2007 J

Case 1 :07-mj—00142—MPT Document 3 Filed 08/06/2007 Page 2 of 3 T
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2. Reason For Detention. The court should detain defendant because there are no ,
conditions of release which will reasonably assure (check one or both): `
__;;__ Defendant’s appearance as required =
___ Safety of any other person and the community I .
3. Rebuttable Presumption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3l42(e). (If yes) The presumption applies because (check q
one or both): A Q
_____ 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 1
____ 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
__Q_(__ After continuance of _?L__ days (not more than 3). S
5. Temporary Detention. The United States request the temporary detention of the
defendant for a period of i days (not more than 10) 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
A of sentence or conviction, or completion of sentence for an offense; I
___ (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. I I p
__>_;_ 3. The defendant may flee or pose a danger to any other person or the I
community. _

Case 1 :07-mj—00142—MPT Document 3 Filed 08/06/2007 Page 3 of 3
6. Other Matters. - i
DATED this day of q` , 2007. l
Respectthlly submitted,
COLM F. CONNOLLY . s
- United States Attorney Q
A . 2 .. [
f H ‘ ‘
Bye ~ `
David L. Hall {
Assistant United States Atto ey ` .