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

Case 1.07-cr-00091-SLR-¥ 13Dp€rIi||egDOZé1?/2Qp g$ge 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. I Criminal Action N0. 07-91 ·Q Lu N QI
CHRISTOPHER J. PHILLIPS, I
Defendant. I
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3142(e) and (f). 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):
L Crime ofviolence (18 U.S.C. § 3156)
K Maximum sentence life imprisonment or death
_ 10+ year drug offense
_ Felony, with two prior convictions in above categories
A Minor victim
_ Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
L Serious risk defendant will flee
_ Serious risk obstruction of justice

Case 1:07-cr-00091-SLR Document 13 Filed 07/12/2007 Page 2 of 3
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
é Safety of any other person and the community
3. Rebuttable Presumgtion. The United States will/will not invoke the rebuttable
presumption against defendant under § 3142(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
¢1€|
specified offensé E P7- Y ?·"T" 3 ) 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
é After continuance of L days (not more than 3).
5. Temporag; 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):
_ 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-00091-SLR Document 13 Filed 07/12/2007 Page 3 013
6. Other Matters.
DATED this 12th day of July , 2007.
Respectfully submitted,
COLM . CONN 0. Y
Uni t * ’ v j,
\ dmond Falg w {
Assistant United tutes Attomey