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

Case 1:05-mj—00084-MPT Document 3 Filed 05/12/2005 Paget of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff,
: Criminal Action No. 05- QH T']
RANDALL HILL, :
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. § 3l42(e) and (f). In support of the motion, the United States
alleges the following:
1. Eligibilig of Case. This case is eligible for a detention order because the case
involves (check all that apply):
L Crime ofviolence (18 U.S.C. § 3156)
__ Maximum sentence life imprisonment or death
__ 10+ year drug offense
__ Felony, wit.h two prior convictions in above categories
__ 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 that will reasonably assure (check one or both):
X Defendant's appearance as required

Case 1:05-mj—00084-MPT Document 3 Filed 05/12/2005 Page 2 of 2
X Safety of any other person and the community
3. Rebuttable Presumption. The United States will not invoke the rebuttable
presumption against defendant under § 3 l42(e). The presumption applies because
(check one or both):
__ Probable cause to believe defendant committed l0+ 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
A After continuance of __; days
DATED this 12th day of May, 2005.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
T ·--. »-
April M. Byrd
Assistant United States Attorney