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

Case 1 :06-mj-00070—lV|PT Document 4 Filed 05/30/2006 |¥f§gd'pf iw O/{JJ
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IN THE UNTTED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE l
UNITED STATES OF AMERICA, )
Plaintiff, 5
)
v. ) Case No. 06- 7ON\
TOMAS LUCAS—IGNACIO z
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. § 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 imprisonment or death
___ 10+ year drug offense
Felony, with two prior convictions in above categories
X! Serious risk defendant will flee
__,____ Serious risk obstruction of justice C
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Case 1:06-mj-00070—IV|PT Document 4 Filed 05/30/2006 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):
X Defendant's appearance as required
_ Safety of any other person and the community
3. Rebuttable Presumption. The United States (will / will not) invokethe rebuttable
presumption against defendant under § 3142(e). (lf 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
4. Time For Detention Hearing . The United States requests the court conduct the
detention hearing,
_ At first appearance
____ After continuance of A 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;

Case 1:06-mj-00070—IV|PT Document 4 Filed 05/30/2006 Page 3 of 3
_ (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 ofthe 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 go day of & , 2006.
COLM F. CONNOLLY
United Sta tt y
BY: /
. Edmo Fal owksi
Assistant U ited States Attorney