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

Case 1 :07-mj-00217-UNA Document 3 Filed 10/31/2007 Page 1 of 1
1 IN THE UNITED STATES DISTRICT COURT I
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ) ii
Plaintiff g
v. l Criminal Action N0. 07- Q I`? P0
RICHARD PARHAM, l [S.D.N.Y. Crim. Act. No. 96-CR-279] ‘
Defendant. l
MOTION FOR DETENTION
NOW COMES the United States and moves for the detention of the defendant, Richard
Parham, pursuant to 18 U.S.C. §§ 3 l43(a) and 35S3(e), and Federal Rules of Criminal Procedure
32.1(a)(6) and 46(d), pending a hearing on the violation of supervised release petition.
In support of the motion, the United States alleges that the defendant poses a danger to
the community, a risk of non-appearance and cannot meet his burden of proving, by clear and
convincing evidence, that he is not likely to pose a risk of flight or danger to the community if
released. The United States further alleges that the defendant cannot demonstrate that he is able
to abide by any condition or combination of conditions of release.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY; [ I M “ M
Christophe .· J; Burk,
Assistant States Attorney
Dated: October 31, 2007 F ``‘·i ii in
l ....,
OCT 3 l 2007
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Case 1:07-mj-00217-UNA

Document 3

Filed 10/31/2007

Page 1 of 1