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

Case 1 :07-cr—OOO52-SLR Document 4 Filed O3/21/2007 Zaggé dfj orc") COLm_1··
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA )
v, g Criminal Action No. 07-
MOHAMEDKAMAL KABIRA l
Defendant. 3 _ _
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendants,
pursuant to 18 U.S.C. § 3l42(e) and (f). In support of the motion, the United States alleges the
following:
l. 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
A 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 IS U.S.C. § 2250
A Serious risk defendant will flee
L Serious risk obstmction ofjustice
2. Reason For Detention. The court should detain the defendant(s) because
there are no conditions of release which will reasonably assure (check one or both): V
A Defendant’s appearance as required [Y _E*b_"T"""`g
A Safety of any other person and the community I I_—`T"T“`"I
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Case 1:07-cr—OOO52-SLR Document 4 Filed O3/21/2007 Page 2 of 3
3. Rebuttable Presumption. The presumption applies because (check one or
both):
L Probable cause to believe defendant(s) committed lO+ 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 l0 days (not more than 10) so that the appropriate officials
can be notified since (check 1 or 2, and 3); i
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. T
_; 2. The defendant is not a citizen ofthe U.S. or lawfully admitted for permanent .
residence.
A 3. The defendant may flee or pose a danger to any other person or the
community.

Case 1:07-cr-00052-SLR Document 4 Filed O3/21/2007 Page 3 of 3
DATED this 21st day of March , 2007.
Respecthlly submitted,
COLM F, CONNOLLY
United States Attorney
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, ‘ X' ssistant United States Attomey
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