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

, _ Case 1:07-cr-OOO48-GIVIS Documepfyz Ogé/0920tE
I ‘ i` 2 §—30»0‘7 EWG
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE I
UNITED STATES OF AMERICA, )
Plaintiff, l
v. g Criminal Action No. 07- §<¢>‘r"" T mp T
TYRONE ROANE, l
Defendant. )
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 (f). In support of the motion, the United States alleges the
following:
1. Eligibilig 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 imprisomnent or death
A 10+ year drug offense
F _ Felony, with two prior convictions in above categories
; Minor victim
A X_ Possession! use of fireann, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250 U
L Serious risk defendant will flee
i _ 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):
_;(__;_ Defendants appearance as required
__}_§___ Safety of any other person and the community
I
H

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3. Rebuttable Presumption. The United States will invoke the rebuttable_
presumption against defendant under § 3l42(e). (lf yes) The presumption applies because
(check one or both):
L Probable cause to believe defendant committed 10+ year drug offense or
l firearms offense, 18 U.S.C. § 924(c), or a federal crime of terrorism, or a specified
offense I ) with minor victim
__ Previous conviction for "eligible" offense committed while on pretrial bond l
4. Time For Detention Hearing. The United States requests the court conduct
the detention hearing,
_ At first appearance
A After continuance of _; 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 l0) so that the appropriate officials can
be notified since (check 1 or 2, and 3): I
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.
1 3. The defendant may flee or pose a danger to any other person or the community.

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6. Other Matters.
DATED this 30th day of March , 2007.
Respectfully submitted, ` ii
COLM F. CONNOLLY
United States Attorney
BY: i M L .
Dougla E. McCann li
Assistant United States Attorney ;
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