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

Case 1 :06-cr-0OO8§§`Qlé% `.IQtoe¥@enb%u(IFi|ed(QFgg3/2006 Page 1 of 3
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_ IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ;
Plaintiff, I
v. Case N0. 06- 3 3 M
STEVEN DAVIS
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 imprisomnent or death
__ 10+ year drug offense
_ Felony, with two prior convictions in above categories
L Serious risk defendant will flee
A Serious risk obstruction of justice
I U L L I .e ;·..·.t.:t.
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Case 1:06-cr—00085-SLR Document 4 Filed 07/13/2006 Page 2 of 3
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
_ 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). (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)
___ Previous conviction for "eligible" offense committed while on pretrial bond V
4. Time For Detention Hearing. The United States requests the court conduct the
detention hearing,
_ At first appearance
L After continuance of _3; days or after any competency hearing ordered by
the Court.
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 be notified since:
1. At the time the offense was committed the defendant was:
__ (a) on release pending trial for a felony;

Case 1:06-cr—00085-SLR Document 4 Filed 07/13/2006 Page 3 of 3 A
_ (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. _
6. Other Matters.
DATED this 13th day of@L, 2006. _
Respectfully submitted,
» COLM F. CONNOLLY
United States Attomey
i/N A [_ ’
BY; l`['__/.»1.--·»·¤-·g»·’”{»,- Z .4
Douglas E. McCann
Assistant United States Attomey