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

Case 1 :07-mj-00110—IV|PT Document 3 Filed 06/01 /2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, _ i
v. i Criminal Action No. 07- [ I QM ‘
MARZETTE KING, )
Defendant. 3
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3l42(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)
__ Maximum sentence life imprisonment or death
____ 10+ year drug offense
___ Felony, with two prior convictions in above categories
___ Minor victim
i _X_ Possession! use of firearm, destructive device or other dangerous weapon
___ Failure to register under 18 U.S.C. § 2250
__§_(_ Serious risk defendant will flee
__ Serious risk obstruction ofjustice
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both)\f4—-· F I
i(__ Defendants appearance as required i
__Q(__ Safety of any other person and the community I JUN ] E;]-U] i T
L Z
_ l . ‘~’e · a _ ..

Case 1:O7—mj-OO110—IV|PT Document 3 Filed 06/O1/2007 Page 2 of 3
3. Rebuttable Presumption. The United States 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 USC. § 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, 3
___ 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 for an offense.
Q_ 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:O7—mj-OO110—lV|PT Document 3 Filed 06/O1/2007 Page 3 of 3
6. Other Matters.
DATED this lst day of June, 2007.
Respectfully submitted,
COLM F. CONNOLLY 0
United States Attorney
BY.
Martin Meltzer it
Special Assistant United States Attorney