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

Case 1 :08-cr-001 10-JJF Document 3 Filed 07/O3/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
v. )
)
AYOMIDE MICHAEL AKINULI, ) Criminal Action No. 08- ll S" Wl
Defendant. l
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3 l42(e) and (I). In support of the motion, the United States alleges the
following:
1. Eligibilig 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
_ Minor victim; possession or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
A 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 1:08-cr-00110-JJF Document 3 Filed 07/O3/2008 Page 2 of 3
___ Safety of any other person and the community
3. Rebuttable Presumption. 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
A 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):
l. 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 1:08-cr-00110-JJF Document 3 Filed 07/O3/2008 Page 3 of 3
DATED this 3rd day of July , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY:
Lesley . Wolf
Assist United States Attorney

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