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

Case 1 :06-mj—OOO37—M PT Document 3 Filed O3/27/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Piamtrt E ‘
v. Criminal Complaint No. 06- 37*1- i ""·'*¤°T-
FRANCISCO BARERRA-LOPEZ,
Defendant.
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the
defendant, FRANCISCO BARERRA-LOPEZ, pursuant to 18 U.S.C. § 3l42(e) and (i). In -
support ofthe 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 ofviolence (18 U.S.C. § 3156) _
____ Maximum sentence life impiisomnent or death
X 10+ year drug offense
__ Felony, with two prior convictions in above categories
A 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 ass1n·e (check one or both):
X Defendanfs appearance as required -
X Safety of any other person and the community
F I L E D
MAH 2 7 2006 _
U.S. UISTRICT COURI
DISTRICT OF DELEHARE

Case 1 :06-mj—OOO37—MPT Document 3 Filed O3/27/2006 Page 2 of 2
3. Rebuttable Presumption. The United States will invoke the rebuttable
presumption against defendant tmder § 3l42(e). (If 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 3 days (not more than 3).
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
Date: March 27, 2006 BY: g'
Adam Safwat
Assistant United States Attomey