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

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, 3
v. g Criminal Action No. 06-81-HF
ROBERT J. HARRIS, JR., g
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. § 3l42(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 of violence (1 8 U.S.C. § 3156)
__ Maximum sentence life imprisonment or death
g_ 10+ year drug offense
__ Felony, with two prior convictions in above categories
K Minor victim; possession or use of firearm destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
K 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):
0/S Defendants appearance as required
x Safety of any other person and the community

Case 1:06-cr-00081—GIV|S Document 4 Filed 08/22/2006 Page 2 of 3
3. Rebuttable Presumgtion. The United States WILL UF invoke the
rebuttable presumption against defendant under § 3142(e). (If yes) The presumption applies
because (check one or both):
K 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
fi After continuance of _3_ 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.

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6. Other Matters.
DATED this 7:2 day of fad l , 2006.
Respectfully submitted,
COLM F. CONNOLLY
United Sta Attcmey
BY:
Edmond Falgowski
Assistant United States Atto