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

t Case 1 :07-cr-00081-JJF Document 3 Filed 05/18/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, )
v, ) Criminal Action No. 07- gl;/72 f /,7/J 7:
JONATHAN JACKSON, l
Defendant. )
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). ln 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
_ Serious risk obstruction of justice
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both): uhh
i_(_ Defendant‘s appearance as required l l. E D M-by
_)L Safety of any other person and the community E _ T T T M E
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Case 1:07-cr-00081-JJF Document 3 Filed 05/18/2007 Page 2 of 3
3. Rebuttable Presumption. The United States will not invoke the rebuttable
presumption against defendant under § 3 142(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
;(__ 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 mr 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-00081-JJF Document 3 Filed 05/18/2007 Page 3 of 3
6. Other Matters.
. IDJ ,,
DATED this I if day ofMay, 200,.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
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BYZ / /` M
Robeit J . Prett if [
Assistant Unite tates Attorney