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

L x Case 1 :07-cr—O0%96[§lI.$IgA2 %;5 zJI?i1ted 07j Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff g
) . . .
v. ) Cnminal Action No. 07-9i?
LEE FRANCIS BLOTZER, g
Defendant. 3
MOTION FOR DETEIETION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3142(e) and (i). 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):
I 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
X Minor victim
1 Possession! use of firearm, destructive device or other dangerous weapon
__P Failure to register under 18 U.S.C. § 2250
A Serious risk defendant will flee
_ Serious risk obstruction of justice

Case 1:07-cr—00096-SLR Document 8 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):
_Z<__ Defenda.nt's appearance as required
1 Safety of any other person a.nd the community
3. Rebuttable Presumption. The United States will/will not invoke the rebuttable
p presumption against defendant under § 3142(e). (If yes) The presumption applies because (check
one or both): ‘
i 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
y specified offense (E") ) 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
K 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):
___ 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;
L (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.

B Case 1:07-cr-00096-SLR Document 8 Filed 07/12/2007 Page 3 of 3
6. Other Matters.
. DATED this 12th day of July ,2007.
I Respectfully submitted,
I *" .CONNO . *
es Alto
.
- Edmond Falgowski r
Assistant United States Attorney