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

Case 1:06-mj-00152-|\/FFIl:`t\l@ultr¥§nta1\Z> &T`Fi|é}1b•L2fH‘!l'r/2 l5|:lél}e 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, ) Crim. Action N0. @5_i§l\»`\
v. ) Criminal Action No. 06-3364-WCT (S.D.
) Florida)
I
IAN BAILEY, )i
I Defendant. g I
MOTION FOR DETENTION HEARING I
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: I
1. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply): · F
__ Crime of violence (18 U.S.C. § 3156) g
__ Maximum sentence life imprisonment or death I DEC 1 9+ ij [
__ 10+ year drug offense uns. MTREJT wm
__ Felony, with two prior convictions in above categorie
__ Minor victim
; Possession! use of firearm, destructive device or other dangerous weapon
. __ Failure to register under 18 U.S.C. § 2250
_;(_ 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):
L Defendant's appearance as required

. Case 1:06-mj-00152—lV|PT Document 4 Filed 12/15/2006 Page 2 of 3
_ Safety of any other person and the community l
3. Rebuttable Presumption. The United States will/will not invoke the
rebuttable presumption against defendant under § 3142(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
A _ 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 L 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
A 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.
1 3. The defendant may flee or pose a danger to any other person or the community.

Case 1:06-mj-00152—IV|PT Document 4 Filed 12/15/2006 Page 3 0f 3
A 6. Other Matters.
DATED this 15th day of December , 2006. _
Respectfully submitted,
COLM F. CONNOLLY
United States Attcrney
·\[ .t_ .
{lla son
Assistant United States Attcrney