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

Case 1 :07-mj-001 1 2—I\/I PT Document 2 Filed 06/22/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT ·
FOR THE DISTRICT OF DELAWARE i
UNITED STATES OF AMERICA, ) i
_ . Plaintiff} g
v. g Criminal Action No. 07-112M E
` RUBEN SANTANA-MILLAN, g
· a/k/a RUBEN PEDROSA-MILLAN )
Defendant. ) -
MOTION FOR DETENTION HEARING I
NOW COMES the United States and _moves for the pretrial detention of the defendant, i
pursuant to 18 U.S;C. § 3142(e) and_ (f). In support ofthe motion, the United States alleges the A
following: _
1. Eligibilig of Case. This case is eligible for a detention order because case {
involves (check all that apply):
_____ Crime ofviolence (18 U.S.C. § 3156)
L Maximum sentence life imprisonment or death g
l ` ___ 10+ year drug offense
I _ Felony, with two prior convictions in above categories ;
. ___ Minor victim; possessionior use of firearm, destructive device or other L
` _ _ dangerous weapon; or failure to register under 18 U.S.C. § 2250
__§__ Serious risk defendant will flee in
M Serious risk obstruction of justice i
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both):
QL Defendant's appearance as required U ·
_ Safety of any other person and the community

I Case 1 :07-mj-00112—IV|PT Document 2 Filed 06/22/2007 Page 2 of 3 I
I 3. Rebuttable Presumption. The United States WlLL NOT invoke the
rebuttable presumption against defendant under § 3 l42(e).' (If yes) The presumption applies
l because (check one or both): l
l _ Probable cause to believe defendant committed 10+ year drug offense or ·
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, l .
_ At first appearance l
S __X_____ After continuance of L_ days (not more than 3). `
A 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): T
. 1. At the time the offense was committed the defendant was:
l _ (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; 5
_ (c) on probation or parole for an offense. i
U _ 2. The defendant is not a citizen of the U.S. or lawfully admitted for pennanent S
residence. .
____ 3. The defendant may flee or pose a danger to any other person or the community. ·

Case 1 :07-mj-00112—IV|PT Document 2 Filed 06/22/2007 Page 3 of 3 A
6. Other Matters.
DATED this 22“d day of June , 2007.
Respectfully submitted, · l
a U com/1 F. coNNoLLY a
United States Attorney ;
gg/0/MMW
Beth oskow-Schnoll
‘ . Assistant United States Attorney