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

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• A IN THE UNITED STATES DISTRICT COURT
I FOR THE DISTRICT OF DELAWARE A _ _
UNITED STATES OF AMERICA, ) an
Plaintiff. g
U v. { Criminal Action No. 07- 122M
DAYWON DRUMMOND, g ‘ I
_ . Defendant. A g .
’ MOTION FOR DETENTION HEARING _ I
NOW COMES the United States and moves for the pretrial detention of the defendant, I
pursuant to 18 U.S.C. § 3142(e) and (f`). In support ofthe motion, the United States alleges the _ 8
following: n · i
1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply): _=___ _ D
l _____ Crime of violence (18 U.S.C. § 3156) p . l .,,.._
_ Maximum sentence life imprisonment or death A I p JUL ,§ Q EQU? ‘ l
___ 10+ year drug offense l ,,__ ,
_ Felony, with two prior convictions in above
y _ Minor victim U
__Xg Possession! use of firearm, destructive device or other dangerous weapon A
_ Failure to register under 18 U.S.C. § 2250 .
‘ _2_{__ Seiious risk defendant will flee l I
;__ Serious risk obstruction of justice n I
2. Reason For Detention. The court should detain defendant because there are l p
no conditions of release which will reasonably assure (check one or both):
p A Defendants appearance as required _ .-
__)_§__ Safety of any other person and the community

Case 1 :07-mj—OO122—MPT Document.5 Filed 07/19/2CtO7 Page 2 of 3
F . 3. Rebuttable Presumption. The United States will/will_not invoke the _. I
l rebuttable presumption against defendant under § 3 l42(e). (If yes) The presumption applies I
because (check one or both): - -
· ______ Probable cause to believe defendant committed 10+ year drug offense or I
_ l fireanns offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified
offense with minor victim l I
_ Previous conviction for "eligible" offense committed while on pretrial bond
- 4. Time For Detention Hearing. The United States requests the court conduct (
I- the detention hearing, _ . S
M l _ At first appearance l
_ _ __L After continuance of _; 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 I
l be notified since (check 1 or 2, and 3): i I
- l. At the time the offense was committed the defendant was: l
l _ (a) on release pending trial for a felony;
. _ i (b) on release pending imposition or execution of sentence, appeal
of sentence or conviction, or completion of sentence for an offense; I
‘ L (c) on probation or parole for an offense. I
_ 2. The defendant is not a citizen ofthe U.S. or lawfully admitted for permanent
l residence .-_.
` ____ 3. The defendant may flee or pose a danger to any other person or the community. i
l
l
l

Case 1 :07-mj—00122—MPT Document 5 Filed 07/19/2007 Page 3 of 3
‘ 6. Other Matters. e U I
§
. DATED this 19th day of July 2007. l
Respectfully submitted, `
COLM F. CONNOLLY .
United States Attorney . - ·
- y · A BY: ( A
_ artin C. Meltzer .
Special Assistant United States Attorney _