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UNITED STATES DISTRICT COURT M _
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DISTRICT OF CONNECTICUT w i`}-M W g XM
UNITED STATES OF AMERICA : Ul`: ` ii
. v. : CRIMINAL NO3 i)0CR243(DJ S)
JOSEPH L. JILES :
GOVERNMENT’S MOTION FOR PRETRIAL DETENTION
Pursuant to Title 18, United States Code, Sections 3142(e) and (f), the Government hereby
requests that the defendant be ordered detained prior to trial.
I. Eligibility of Case
This case is eligible for pretrial detention because it involves: l
_ a crime of violence as defined in Title 18, United States Code, Section 3156;
__ an offense for which the maximum sentence is life imprisonment or death;
l an offense for which a maximum term of imprisonment
of ten years or more is prescribed in the Controlled Substances Act (21
U.S.C. § 802, et gl.), the Controlled Substances Import and Export Act (21 U.S.C.
§ 951, gt sgq.), or Section 1 ofthe Act of September 15, 1980 (21 U.S.C. § 955a);
_ any felony committed after the defendant has been convicted of two or more of the
prior two offenses or two or more State or local offenses that would have been one
of the prior two offenses if a circumstance giving rise to Federal jurisdiction had
existed;
!___ a serious risk that the defendant will flee; and/or
N
- )
` ` Case 3:OO—cr-OO24%·a¤>WT Document 63 Filed O1/1€.iP)OO5 Page 2 of 3
__ a serious risk that the defendant will obstruct or attempt to obstruct justice, or
threaten, injure, or intimidate, a prospective witness or juror.
H. Reason for Detention
The Court should detain defendant because there are no conditions of release which will
reasonably assure: i
_|L_ the defendant's appearance as required; and/or I
L_ the safety of any other person and the community.
Ill. Rebuttable Presumption
The Govemment will not invoke the rebuttable presumption against the defendant under Title i
18, United States Code, Section 3 l42(e). The presumption applies because:
m___ the defendant has been convicted of a Federal offense described in Title 18, United
States Code, Section 3 l42(f)(l) or of a State or local offense that would have been
an offense described in Section 3l42(t)(l) if a circumstance giving rise to Federal
jurisdiction had existed;
__ an offense described in Title `l8, United States Code, Section 3l#42(e)(l) was
committed while the defendant was on release pending trial for a Federal, State, or
local offense; and ‘
__W___m_ a period of not more than five years had elapsed since the date of conviction, or the L
release of the defendant from imprisonment, for an offense described in Title 18, E
United States Code, Section 3l42(e)(1), whichever is later; or
l
_ there is probable cause to believe that the defendant committed an offense for which i
a maximum term of imprisonment of ten years or more is prescribed in the
2
E H Case 3:00-cr-0024%-A)WT Document 63 Filed 01/1 · 005 Page 3 of 3 i
T, 1
Controlled Substances Act (21 U.S.C. § 801, et seq.), the Controlled Substance
. Import and Export Act (21 U.S.C. § 951, et gi.), Section 1 ofthe Act of September
15, 1980 (21 U.S.C. § 955a), or an offense under Section 924(c) of Title 18 ofthe
United States Code.
IV. Time for Detention Hearing
The Government requests that the Court conduct the detention hearing: -
V at the defendant's first appearance;
after a continuance of (not more than 3) days. `
Respectfully submitted, I
KEVIN J. O’CO OR I
UNITED S T I AT ORNEY
THOMAS V. ILY
ASSISTANT UNITE STATES ATTORNEY
450 Main Street, Room 328
Hartford, Connecticut 06103 J
Tel. (860) 947-1101
Federal Bar No. ct 03467 {
CERTIFICATION
I hereby certify that a copy of the foregoing was hand delivered this 18th day of January,
2005, to:
Terence S. Ward, Esq.
Assistant Federal Public Defender
241 Main Street, 15* Fl. So. ;
Hartford, CT 06106 I
THO S V. DAIL
ASSISTANT UNITED STA S ATTORNEY
1
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