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

Case 1 :06-mj—OOO37—M PT Document 5 Filed O3/27/2006 Page 1 of 2
. IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Piaimirg Q
v. Criminal Complaint N0. 06- 370/I· 2 '“ *4·FT_
SALVADOR MARTINEZ-TORRES,
Defendant. I
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MOTION FOR DETENTION HEARING [
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NOW COMES the United States and moves for the pretrial detention of the I
defendant, SALVADOR MARTlNEZ—TORRES, pursuant to 18 U.S.C. § 3l42(e) and (t). In
support ofthe motion, the United States alleges the following: Z
1. Eligibilig; of Case. This case is eligible for a detention order because the case
involves (check all that apply): i
___ Crime ofviolence (18 U.S.C. § 3156)
_ Maximum sentence life imprisonment or death
_; 10+ year drug offense i
I ___ Felony, with two prior convictions in above categories i
L Serious risk defendant will flee
__ Serious risk obstruction of justice j
2. Reason For Detention. The court should detain defendant because there are
no conditions of release which will reasonably assure (check one or both): i
___);__ Defendants appearance as required I
A Safety of any other person and the community
F I L E 0
A { MAR 27 2000 { i
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Case 1 :06-mj—OOO37—MPT Document 5 Filed O3/27/2006 Page 2 of 2
3, Rebuttable Presumption. The United States will invoke the rebuttable
presumption against defendant under § 3142(e). Cf yes) The presumption applies because
(check one or both):
A 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 I
the detention hearing, i
_ At first appearance
__X_ After continuance of ___3”___ days (not more than 3).
a it
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney ` ;
Date: March 27, 2006 BY: M : Q
dam Safwat .
Assistant United States Attomey Q
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