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

Case 1:05-cr-00038-SLR

Document 4

Filed 04/29/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE UNITED STATES OF AMERICA, Plaintiff, v. TYRONE WILLIAMS, Defendant. ) ) ) ) ) No. 05-38

MOTION FOR DETENTION HEARING NOW COMES the United States and moves for the pretrial

detention of the defendant, pursuant to 18 U.S.C. §3142(e) and (f). In support of the motion, the United States alleges the following: 1. Eligibility of Case. This case is eligible for a

detention order because case involves (check all that apply): X 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 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 assure (check one or both): X X Defendant's appearance as required Safety of any other person and the community

Case 1:05-cr-00038-SLR

Document 4

Filed 04/29/2005

Page 2 of 2

3.

Rebuttable Presumption.

The United States (will, will

not) invoke the rebuttable presumption against defendant under §3142(e). (If 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 than 3). DATED this 29th day of April , 2005. 3 days (not more

COLM F. CONNOLLY United States Attorney

BY: /s/ Richard G. Andrews First Assistant U. S. Attorney