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

Case 1 :07-mj-001 1 3—I\/I PT Document 2 Filed 06/22/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT -
` FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ) I
C Plaintiff] i A
v. g Criminal Action No. 07—113l\/I i
ALFREDITO CAl\/[PUSANO, 3
a/l Defendant. g
MOTION FOR DETENTION HEARING -
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3l42(e) and (f). In support of the motion, the United States alleges the .
i following: i
‘ 1. Eli ibili of Case. This case is eligible for a detention order because case
involves (check all that apply): _ I p
________ Crime ofviolence (18 U.S.C. § 3156) C
_ =. Maximum sentence life imprisonment or death i
is _ 10+ year drug offense
- _ Felony, with two prior convictions in above categories ,
I _ Minor victim; possession or use of firearm, destructive device or other ‘
l l dangerous weapon; or failure to register under 18 U.S.C. § 2250 I
A Serious risk defendant will flee ‘
_ Serious risk obstruction of justice i _ 2
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both): E
l U _____)_§___ Defendants appearance as required _
_ Safety of any other person and the community in

i Case 1:07-mj-00113—IV|PT Document 2 Filed 06/22/2007 Page 2 of 3
3. Rebuttable Presumption. The United States WILL NOT invoke the
rebuttable presumption against defendant under § 3 l42(e). (If yes) The presumption applies
because (check one or both): i
_ Probable cause to believe defendant committed 10+ year drug offense or
i firearms offense, 18 U.S.C. § 924(c)
___ 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
‘ L_ 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): y
1. At the time the offense was committed the defendant was: _ i
__ (a) on release pending trial for a felony; I
T _ (b) on release pending imposition or execution of sentence, appeal
l of sentence or conviction, or completion of sentence for an offense; 5
__ (c) on probation or parole for an- offense. l
__ 2. The defendant is not a citizen of the U.S. or lawfully admitted for permanent l
residence.
_ 3. The defendant may flee or pose a danger to any other person or the community.

Case 1:07-mj-00113—IV|PT Document 2 Filed 06/22/2007 Page 3 of 3
6. Other Matters.
l DATED this 22“d day of June , 2007.
‘ Respectfully submitted,
· COLM F., CONNOLLY _
. A _ United States Attorney T
` __ Beth Moskow-Schnoll
. ‘ Assistant United States Attorney