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

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Case 1:06-mj-OO088—IV|PT Document 2 Fnled 07/21/200&'(·@Qge’i}o 2_
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OE AMERICA, )
Plaintiff, )
v. ) No. 06— ___
ANTHONY MARK BRISCOE, ) JVI L_ __m ;
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Defendant. ) {
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MOTION FOR DETENTION HEARING CTECVYDHNMH
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. 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
X 10+ year drug offense
Felony, with two prior convictions in above
categories
X 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):
X Defendant's appearance as required

Case 1:06-mj-00088—IV|PT Document 2 Filed 07/21/2006 Page 2 of 2
X Safety of any other person and the community
3. Rebuttable Presumption. The United States (will, will
not) invoke the rebuttable presumption against defendant
under §3142(e). (1f yes) The presumption applies because
(check one or both):
X 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
X After continuance of not more than 10
business days, because defendant is on
probation/parole in Pennsylvania, and may flee
or pose a danger to the community. See 18
U.S.C. §3142(d)(1)(iii) & (2).
DATED this 21st day of July , 2006.
COLM F. CONNOLLY
United States Attorney
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BY; ·“ · "
Richard G. Andrews
First Assistant U. S. Attorney