FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, )
v. ) Criminal Action N0. 06- Q l~J\
MANUEL ORTIZ-CAMACHO )
Defendant. 3
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(d), (e) and (f). ln support of the motion, the United States alleges
the following:
1. Eligibility of Case. This case is eligible for a detention order because case
involves (check all that apply):
_ Crime of violence (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; possession or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
A 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):
L Defendant's appearance as required
__ Safety of any other person a11d the community
.s-_ Case 1 :06-mj-00142-IVIPT Document 4 Filed 11/17/2006 Page 2 of 3
3. Rebuttable Presumption. The United States WILL NOT invoke the
rebuttable presumption against defendant under § 3142(e). (If yes) The presumption applies
because (check one or both): ' A
_ 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, A
__ At first appearance
L After continuance of A 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 1:06-mj—00142—MPT Document 4 Filed 11/17/2006 Page 3 of 3
6. Other Matters.
DATED this 17th day of November , 2006.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: J
Robert F. Kravetz . -
Assistant United States y • ey
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