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

I Case 1 :07-mj-00153-UNA Document 3 Filed 08/22/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
l . . .
v. ) Criminal Action No. 07—
THOMAS RIVERS, )
Defendant. )
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention ofthe defendant,
pursuant to 18 U.S.C. § 3l42(e) and (f). In support of the motion, the United States alleges the
following:
1. Eligibility 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
_ 10+ year drug offense
_ Felony, with two prior convictions in above categories
_ Minor victim
_X_ Possession! use of firearm, destructive device or other dangerous weapon
_ ; Failure to register under 18 U.S.C. § 2250
_ QL Serious risk defendant will flee
1 Serious risk obstruction of justice
2. geason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both):
g(_ Defendant's appearance as required V i ~i.. E D }
L Safety of any other person and the community
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"J?i°§iY2i`&`i;0uRt
_ &>l$TRl@T OF DELAWARE k

A Case 1:07-mj-00153-UNA Document 3 Filed 08/22/2007 Page 2 of 3
presumption against defendant under § 3142(e). (lf 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
i__ After continuance of L 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.

0 Case 1 :07-mj—00153-UNA Document 3 Filed 08/22/2007 Page 3 of 3
6. Qther Matters.
DATED this 22nd day of Agjust, 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attomey
BY; / { i t dh/f WMM/2<>
Robe _ Pr an
Assistzi Umted States Attomey
' ` `°'`'' "W


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