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

Case 1:05-mj-00054 Document 4 Filed O3/18/2005 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, )
v. ) No. 05-5qpq
TIMOTHY WADE JACKSON )
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. §3l42(e) and (f). In support
of the motion, the United States alleges the following:
1. Eligibility of Case. This case is eligible forza detention
order because case involves (check all that apply):
Crime of violence (18 U.S.C. § 3156)
Maximum sentence life imprisonment or death
X 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):

Case 1:05-mj-00054 Document 4 Filed O3/18/2005 Page 2 of 3
X Defendant's appearance as required
Safety of any other person and the community
3. Rebuttable Presumption. The United States (glll, 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 3 days (not more than
3).
5. Temporary Detention. The United States requests the
temporary detention of the defendant for a period of __
days (not more than 10) so that the appropriate officials
can be notified since:
1. At the time the offense was committed the defendant
was:
____ (a) on release pending trial for a felony;

Case 1:05-mj-00054 Document 4 Filed O3/18/2005 Page 3 of 3
(b) on release pending imposition or
execution of sentence, appeal of sentence
or conviction, or completion of sentence
for an offense;
(c) on probation or parole for an offense.
2. The defendant is not a citizen of the U.S. or
lawfully admitted for permanent residence.
3. The defendant may flee or pose a danger to any
other person or the community.
6. Other Matters. §
FQ!
FL _..-- sf
DATED this day of i‘‘ *‘ll y 2005.
COLM F. CONNOLLY
Unitee States Attorney
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BY Z . `i.,. ¢. ._ r
FerrFs_W. Wharton
Assi} ant U. S. Attorney