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

Case 1 :07-cr-00078-JJF Document 4 Filed 06/14/2007 Page 1 of 2
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
v. l
WADE GRAY , l Criminal Action N0. 07-78-HF
Defendant. l
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 (t). 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):
__ Crime ofviolence (18 U.S.C. § 3156)
P ___ Maximum sentence life imprisonment or death
___ 10+ year drug offense
__ Felony, with two prior convictions in above categories
___ Minor victim; possession or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250 _
L 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):
_ _i(_ Defendants appearance as required
_;_ Safety of any other person and the community

[I __ ceeemi :07ecr-00078jdF Document 4 Filed 06/14/2007 Page 2 of 2
3. Rebuttable Presumption. 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)
__ 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 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):
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.
1 2. The defendant is not a citizen of the U.S. or lawfully admitted for permanent
residence.
I ___ 3. The defendant may flee or pose a danger to any other person or the community.
DATED this 13th day of June , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney `
BY: g gg-IF?
a H. Eisen in
. ssistant United States Attorney