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

Case 1:06-mj-00085—IV|PT D0cument3 Filed 07/18/2006 Page1 0f2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, )
v. ) No. 06- ?§’M-[y1_l']/
% F I L E u 1
SERGIO ALEJANDRO ARREOLA—MOLINA ) E ___ F
Defendant. ) I ,, . Q \
MOTION FOR DETENTION HEARING l J E
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NOW COMES the United States and moves fo tbeglpretii§I£·~--i
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
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

Case1:06—mj-00085—IV|PT D0cument3 Filed 07/18/2006 Page20f2
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). (If yes) The presumption applies because
(check one or both):
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 3 days (not more
than 3).
DATED this 18th day of July , 2006.
COLM F. CONNOLLY
United States Attorney
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BY: · — ·M»r7V©U/L- //»~
Richard G. A drews
First Assistan U. S. Attorney