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

Case 1 :06-mj—OOO37—I|l/I Pt I oB$neniv I l liinieleilicaizi/acc? —t¥eQeF Et ai I- I- 1
~ IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, : n
Pieinnrn E
v. Criminal Complaint No. 06- 3.]..1 ... 3 · M PT" `
JOSE LUIS BECERRA—YEPEZ,
Defendant. S A
MOTION FOR DETENTION HEARING
_ NOW COMES the United States and moves for the pretrial detention of the
defendant, JOSE LUIS BECERRA-YEPEZ, pursuant to 18 U.S.C. § 3 142(e) and (t). In support
of the motion, the United States alleges the following:
1. Eligibility of Case. This case is eligible for a detention order because the case
involves (check all that apply):
___ Crime of violence (18 U.S.C. § 3156)
___ Maximum sentence life imprisomnent or death
I _i(_ 10+ year drug offense
___ Felony, with two prior convictions in above categories
_L_ Serious risk defendant will flee
___ Serious risk obstruction of justice
A 2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both):
_§_(_ Det`endant's appearance as required
gg Safety of any other person and the commtmity .-.... -...
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· Case 1 :06-mj—OOO37—MPT Document 7 Filed O3/27/2006 Page 2 of 2
3. Rebuttable Presumption. The United States will invoke the rebuttable
presumption against defendant under § 3 l42(e). (lf yes) The presumption applies because
(check one or both):
1 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 3 days (not more than 3).
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
Date: March 27, 2006 BY:
. Adam Safwat
Assistant United States Attorney