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

. , Case 1 :07-cr-00019-JJF Document 8 Filed O3/O1 /Zgléjgage-11 cgfggfé CGJCF
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, )
v. ) Criminal Action No. 07-19
MARIO T. WOODING, )
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 (i). In support ofthe 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 imprisonment or death
&_ 10+ year drug offense
__ Felony, with two prior convictions in above categories
1 Minor victim
Possession/ use of firearm, destructive device or other dangerous weapon
__ Failure to register under 18 U.S.C. § 2250
Serious risk defendant will Hee
_ Serious risk obstruction of justice

Case 1:07-cr-00019-JJF Document 8 Filed O3/O1/2007 Page 2 of 3
2. Reason For Detention. The court should detain defendant because there are no
conditions ofrelease which will reasonably assure (check one or both):
é Defendant's appearance as required
Safety of any other person and the community
3. Rebuttable Presumption. The United States will/will not invoke the rebuttable
presumption against defendant under § 3 l42(e). (lf 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),
_ 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
L 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):
_ 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.
_ 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 1:07-cr-00019-JJF Document 8 Filed O3/O1/2007 Page 3 of 3
6. Other Matters.
DATED this [ S/K/day of il Q fu"! A/K ,2OOZ
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Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
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Assistant United States Atto y