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

Case 1:O7—il(r1jFOd§5\1—I\2¤P¤T epliwcurnentré} _§i’_g<;l tig;/Q2/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff S
v. g Criminal Action N0. 07- 51 M
Thomas L. Davis, Jr., g
Defendant. l
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:
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
__ 10+ year drug offense
___ 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
j_ Serious risk defendant will flee
___ 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):
_2(__ Defendant's appearance as required 1 lc l D l
A Safety of any other person and the community { I I rl M M
1 . L A * r
'
if if .ii*r F i

Case 1:O7—mj-OO051—IV|PT Document 3 Filed O3/22/2007 Page 2 of 3
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):
_ Probable cause to believe defendant committed 10+ year drug offense or
firearms offense, 18 U.S.C. § 924(c), or a federal crime ofterrorism, 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,
1 At first appearance
A 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 _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.
; 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-OO051—IV|PT Document 3 Filed O3/22/2007 Page 3 of 3
6. Other Matters.
DATED this 22nd day ofMarch, 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
/ u
{H z _ ___
BY: ,; gg,
Seth Beausang
Assistant United States Attomey