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

Case 1 :07-cr-00071-JJF Document 18 Filed 06/27/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE _
UNITED STATES OF AMERICA, :
y Pumarr; E
v. I Criminal Action No. 07-71-04 JJF
CHRISTOPHER BAXTER, I
Defendant. I
MOTION FOR DETENTION HEARING I
~ NOW COMES the United States and moves for the pretrial detention of the defendant, I
I pursuant to 18 U.S.C. § 3142(e) and (f). In support of the motion, the United States alleges the
following: I
I ) 1. Eligibilig of Case. This case is eligible for a detention order because case
involves (check all that apply): I
_ Crime ofviolence (18 U.S.C. § 3156)
___ Maximum sentence life imprisonment or death
é 10+ year drug offense
I- _ Felony, with two prior convictions in above categories I
_ Minor victim I
, _ _ _ Possession! use of fireann, destructive device or other dangerous weapon I
+*__ Failure to register under 18 U.S.C. § 2250 -
L Serious risk defendant will flee p
I ____ Serious risk obstruction of justice _
2. Reason For Detention. The court should detain defendant because there are p
no conditions of release which will reasonably assure (check one or both): j
. - L Defendants appearance as required ‘ I
` _ ;(_____ Safety of any other person and the community

Case 1I:07—cr-00071-JJF Document 18 Filed 06/27/2007 Page 2 of 3
I 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): __
L 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 ( J with minor victim
L 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,
_ L At first appearance
i L After continuance of _3_ days (not more than 3). _
5. Temporary Detention. The United States request the temporary detention of .
I the defendant for a period of Ldays (not more than 10) so that the appropriate officials can ‘
I be notified since (check 1 or 2, and 3): I i
l. At the time the offense was committed the defendant was:
L (a) on release pending trial for a felony;
I I ____ (b) on release pending imposition or execution of sentence, appeal I
I - of sentence or conviction, or completion of sentence for an offense; I
I ____ (c) on probation or parole for an offense. tI
I L 2. The defendant is not a citizen ofthe U.S. or lawfully admitted for permanent
I residence. . I
I ______ 3. The defendant may flee or pose a danger to any other person or the community. I
. l

Case.1 :07-cr-00071-JJF Document 18 Filed 06/27/2007 Page 3 of 3
- . 6. Other Matters.
DATED this 27th day of June, 2007.
· Respectfully submitted,
I COLM F. CONNOLLY .
United States Attorney A
_ BY: U L;
Dougla E. McCann
Assist t United States Attorney