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

Case 1 :06-cr-00029-JJF Document 4 Filed O3/24/2006 Pa 1 of 2
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff
v. Criminal Complaint No. O6— 3 (0 N]
SILVIA LANDA-MARTINEZ
Defendant.
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the
defendant, pursuant to 18 U.S.C. § 3 l42(e) and (lj. 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 imprisonment or death
_ 10+ year drug offense
_ Felony, with two prior convictions in above categories
L 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):
A Defendanfs appearance as required
__ Safety of any other person and the community
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Case 1:06-cr-00029-JJF Document 4 Filed O3/24/2006 Page 2 of 2
3. Rebuttable Presrrmption. The United States will not invoke the rebuttable
presumption against defendant under § 3142(e). Uf 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 E day of March, 2006.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
By; Q
Adam Safwat
Assistant United States Attorney