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

_ Case 1 :06-cr-00104-GMS Document 3 Filed 09/12/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
1 FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, ) I
v. ) Case No. 06-105M
STEPHANIE GRAY, )
- Defendant. )
F MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. §3 l42(e) and (f). In support of the motion, the United States alleges the
following:
1. Eligibility of Case. This case is eligible for a detention order because ease
involves (check all that apply):
_ Crime ofviolence (18 U.S.C. § 3156)
_____ Maximum sentence life imprisonment or death p
{ 10+ year drug offense
; Felony, with two prior convictions in above categories
__________ Serious risk defendant will flee
U __ Serious risk obstruction of justice F I L E D
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, Case 1:06-cr-00104-GIVIS Document 3 Filed O9/12/2006 Page 2 of 3
2. Reason For Detention. The co1u·t should detain defendant because there are
no conditions of release which will reasonably assure (check one or both):
__ Defendant's appearance as required
[Safety of any other person and the community
3. Rebnttable Presumption. The United States (will, will not) invoke the
rebuttable presumption against defendant under §3 142(e). (If yes) The
presumption applies because (check one or both):
L 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
i bond
4. Time For Detention Hearing. The United States requests the court conduct the
detention hearing,
_ At first appearance
____\{ After continuance of iw days (not more than 3). y
q 5. Temporary Detention. The United States requests the temporary detention of
the defendant for a period of ___ days (not more than 10) so that the
appropriate officials can be notified since:
1. At the time the offense was committed the defendant was:
_____ (a) on release pending trial for a felony;

_ Case 1 :06-cr-00104-GMS Document 3 Filed 09/12/2006 Page 3 of 3
(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.
6. Other Matters.
DATED this /2% day or §,gf'¢·•·£-•~ , 2006.
COLM F. CONNOLLY;
United States Attorney