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

Case 1:07-cr-00123-SLR

Document 3

Filed 08/28/2007

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. TARIREEF WHITE, Defendant.
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) Criminal Action No. 07- [d

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MOTION FOR DETENTION HEARING NOW COMES the United States and moves for the pretrial detention of the defendant,

3 In pursuant to 18 U.S.C. j 142(e) and (0. support of the motion, the United States alleges the
following: 1. Eli~ibilitv Case. This case is eligible for a detention order because case of involves (check all that apply):

Maximum sentence life imprisonment or death 10+ year drug offense Felony, with two prior convictions in above categories Minor victim
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Possession/ use of firearm, destructive device or other dangerous weapon Failure to register under 18 U.S.C. j 2250

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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):
X

Defendant's appearance as required Safety of any other person and the community

X

Case 1:07-cr-00123-SLR

Document 3

Filed 08/28/2007

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3. Rebuttable Presumption. The United States will not invoke the rebuttable presumption against defendant under § 3 142(e). (If 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), or a federal crime of terrorism, or a specified offense (
) with minor victim

-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

X After continuance of 3

days (not more than 3).

5. Temporary Detention. The United States requests 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; (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 1:07-cr-00123-SLR

Document 3

Filed 08/28/2007

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6. Other Matters.

DATED this

28th

day of Aumst, 2007 Respectfully submitted, COLM F. CONNOLLY United States Attorney
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BY:
Special Assistant United Stat s A orney

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