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

Case 1 :06-cr-00109-JJF Document 8 Filed 03/01 /2007 Page 1 of 3 to
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IN THE UNITED STATES DISTIUCT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, l
v. g Criminal Action N0. 06-109
ERIC BLACKMON, 1 i
Defendant. g
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)
__)L 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
L Serious risk defendant will flee
; Serious risk obstruction ofjustice
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both):
_j(_ Defendant's appearance as required
_L_ Safety of any other person and the community

Case 1:06-cr-00109-JJF Document 8 Filed O3/O1/2007 Page 2 of 3
3. Rebuttable Presumption. The United States WILL invoke the rebuttable
presumption against defendant under § 3142(e). (1f yes) The presumption applies because
(check one or both):
A Probable cause to believe defendant committed 10+ year dwg offense or
firearms offense, 18 U.S.C. § 924(c)
_ Previous conviction for "e1igib1e" offense committed while on pretrial bond
4. Time For Detention Hearing. The United States requests the court conduct
the detention hearing,
+ At first appearance
A After continuance 0fL 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 ofthe U.S. or lawfully admitted for pemianent
residence.
_ 3. The defendant may fiee or pose a danger to any other person or the community.

Case 1:06-cr-00109-JJF Document 8 Filed O3/O1/2007 Page 3 of 3
6. Other Matters.
DATED this lst day of March , 2007.
Respectfully submitted,
COLM F. CONNOLLY
United States Attomey
I II / ( II. . l f _-é
BY: _/x/L wo, L- { _ J levy---
Douglaspé. McCann
Assistant United States Attorney