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

Case 1:04-mj-00014—IV|PT Document 21 Filed 05/21/2007 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT _
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Criminal Action No. 04-14M MPT
)
DAWN MUMMERT, )
)
Defendant. )
MOTION FOR DETENTION
NOW COMES the United States and moves for the detention of the defendant,
Dawn Mummert, pursuant to 18 U.S.C. §§ 3143(a) and 3148(b) and Federal Rules of Criminal
Procedure 32.1(a)(6) and 46, pending a hearing on the violation of supervised release petition. In
support of the motion, the United States alleges that the defendant poses a risk of non-appearance
and cannot meet her burden of proving, by clear and convincing evidence, that she is not likely to
pose a risk of flight if released. The United States further alleges that the defendant cannot
demonstrate that she is able to abide by any condition or combination of conditions of release.
Respectfully submitted,
COLM P. CONNOLLY
United States Attorney
nr`} _
BY: I _./ t-`»Vf` ll/F Iii;
Douglas E. McCann
Assistant United States Attorney
Dated: May 21, 2007

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