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

I Case 1 :07-cr-00067-SLR Document 3 Filed 05/16/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff ) ·
v, ) Criminal Action No. 07— / U [ M ·— M [G1}
KADARELL BARRETT, i
` Defendant. g
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3l42(e) and (f). In support of the motion, the United States alleges the
following:
· l. Eligi ibilig of Case. This case is eligible for a detention order because case
involves (check all that apply):
A ___ Crime of violence (18 U.S.C. § 3156) H if if iilii- in
_; Maximum sentence life imprisonment or death M nll ii if
- .l"l/l\Y152UU7/
i 10+ year drug offense I
_ Felony, with two prior convictions in above categorie l l p ll
i _ ___ Minor victim I i
_X_ Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250 U
__; Serious risk defendant will flee
___ 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 Defendants appearance as required _
L_ Safety of any other person and the community

Case 1:07-cr-00067-SLR Document 3 Filed 05/16/2007 Page 2 of 3
3. Rebuttable Presumption. The United States will not invoke the rebuttable
presumption against defendant under § 3 l42(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
L After continuance of`; 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 U
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-00067-SLR Document 3 Filed 05/16/2007 Page 3 of 3
6. Other Matters. n l -
DATED this 16th day of May, 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
Robert J. P an .
Assistant United States Attorney