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

Case 1 :07-cr-00075—GIV|S Document 9 Filed 06/28/2007 Page 1 of 3
—X— Filed `· io eyen court olaslcrz @
._ UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA :
: Criminal Action No. 07-75-GMS
PlaintifrQ 2
v. :
CALVIN A. PETERSON,
Defendant. ·
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention ofthe defendant,
pursuant to 18 U.S.C. § 3l42(e) and (f). In support of the motion, the United States alleges the
following:
I. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply):
___ Crime ofviolence (IS U.S.C. § 3l56)
__ Maximum sentence life imprisonment or death
__ 10+ year drug offense A
__ 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
_)_L Serious risk defendant will flee if released from federal and state custody
__ 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):
j_{_ Defendant's appearance as required

Case 1 :07-cr-00075—GIV|S Document 9 Filed 06/28/2007 Page 2 of 3
L Safety of any other person and the community
x 3. Rebuttable Presumption. The United States will/will not invoke the
rebuttable presumption against defendant under § 3142(e). (If 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
_X_ After continuance of i__ 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): A
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 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.

Case 1:07-cr-00075-GIVIS Document 9 Filed 06/28/2007 Page 3 of 3
6. Other Matters.
DATED this 28th day of June 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: Q; %
Set M. Beausang _
Assistant United States Attorney