- /
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff g
. v. g Criminal Action No. 08-24-l\/I
MARK TRAVIS, g
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. § 3l42(e) and (f). In support of the motion, the United States alleges the
1 following:
1. Eligibiligg 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
A, 10+ year drug offense
__ Felony, with two prior convictions in above categories
_ Minor victim
_wX_ Possession! use of firearm, destructive device or other dangerous weapon
__W_ Failure to register under 18 U.S.Ci § 2250
A Seriousrisk defendant will flee
_h* 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); p
A Defendants appearance as required
L Safety of any other person and the community
’ J I Case 1:08-mj—OOO24—UNA Document 3 Filed O2/07/2008 Page 2 of 3
3. Rebuttable Presumption- The United States will/will not invoke the
rebuttable presumption against defendant under § 3 1 42(e). (If yes) The presumption applies
because (check one or both):
__)L 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
_M 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
QL 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 pennanent
U residence.
1y 3. The defendant may flee or pose a danger to any other person or the community.
Case 1:08-mj—OOO24—UNA Document 3 Filed O2/07/2008 Page 3 of 3
6. Other Matters. _
DATED this 7th day of February , 2008.
Respectfully submitted,
/ J
COLM F. ONNOLLY
Unite tes Attorney
BY: I
"' A. Weede .
·· stant United States Attorney
Case 1:08-mj-00024-UNA
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