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

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IN THE UNITED STATES DISTRICT COURT
F OR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. g Criminal Action N0. 07-104M
SCOTT T. ROBINSON, g
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. § 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)
_ Maximum sentence life imprisonment or death _
_ 10+ year drug offense
_ Felony, with two prior convictions in above categories
L 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
F I L E D
MAY I 8 2007
D%é?¤€¥?l§?“'élE?Jt’§lr

g Case 1:07-cr—00082-SLR Document 6 Filed 05/18/2007 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
i Safety of any other person and the community
3. Rebuttable Presumption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3l42(e). (If yes) The presumption applies because (check
one or both):
A Probable cause to believe defendant committed
, or a
specified offense (I 8 US C 2 2; ZA l 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
L After continuance of _j__ 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 l0) so that the appropriate officials can be
notified since (check 1 or 2, and 3): V
_ l. 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.

.r Case 1:07-cr—00082-SLR Document 6 Filed 05/18/2007 Page 3 of 3
6. Other Matters.
DATED this [S day of il); w _{ ,2007.
Respectfully submitted,
COLM F. CONNOLL
United s Attcrne
By: U
Edmc d Falgcwsk
Assistant United States At cmey