Free Motion to Revoke - District Court of Delaware - Delaware

__ Case 1 :06-cr-00079-GIVIS Document 13 Filed 06/26/2007 Page 1 of 2
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, g
v. 3 Criminal Action No. 06-79-GMS
RITCHIE JACKSON, g
Defendant. g
MOTION FOR REVOCATION OF ORDER OF
PRE-TRIAL RELEASE AND DETENTION PENDING TRIAL
NOW COMES the United States of America, by and through its attorneys, Colm
F. Connolly, United States Attorney for the District of Delaware, and Beth Moskow-Schnoll,
Assistant United States Attorney, and, pursuant to 18 U.S.C. § 3l48(b), hereby moves for the
revocation ofthe Court’s order of pre-trial release of the defendant, and further moves for the
pre-trial detention of the defendant, pursuant to Federal Rules of Criminal Procedure 32.l(a)(6)
and 46(d).
In support of this motion, the United States alleges as follows: (a) there is clear
and convincing evidence that the defendant has violated one or more conditions of his release;
(b) based on the factors set forth in 18 U.S.C. § 3l42(g), there is no condition or combination of
conditions of release that will assure that the defendant will not flee; and ( c) the defendant is
f I L E D
` JUN 2 6 2007 }
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='' Case 1:06-cr-00079—G|\/IS Document 13 Filed 06/26/2007 Page 2 of 2
unlikely to abide by any condition or combination of conditions of release.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney X I _
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Beth Moskow-Schnoll
Assistant United States Attorney .
Dated: June 26, 2007