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

Case 1 :08-cr-00137-UNA Document 2 Filed 08/18/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA )
v. g
) Criminal Action No. 08- jq'3 M
JEFFREY DANIELS )
KENNETH KILSON )
Defendants. )
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendants,
pursuant to 18 U.S.C. § 3142(e) and (f). In support of the motion, the United States alleges the
following:
1. Eligibilig; of Case. This case is eligible for a detention order because case involves (check
all that apply):
__ Crime ofviolence (18 U.S.C. § 3156)
_ Maximum sentence life imprisonment or death
_L_ 10+ year drug offense
___ Felony, with two prior convictions in above categories
___ Minor victim; possession or use of firearm, destructive device or other
dangerous weapon; or failure to register under 18 U.S.C. § 2250
_2(_ Serious risk defendant will flee
_ Serious risk obstruction of justice
2. Reason For Detention. The court should detain the defendant(s) because there are no
conditions of release which will reasonably assure (check one or both):
L Defendant’s appearance as required
A Safety of any other person and the community V F l gw D
1
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U.S. DISTRICT COURT l
DISTRECTOFDEIAE/}jL_M __g_‘ ___;

Case 1:08-cr-00137-UNA Document 2 Filed 08/18/2008 Page 2 of 2
3. Rebuttable Presumption. The presumption applies because (check one or both):
L Probable cause to believe defendant(s) 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
A After continuance of _j_ days (not more than 3).
5. Temporary Detention. The United States request the temporary detention of the defendant
for a period of __days (not more than 10) so that the appropriate officials can be notified
since (check 1 or 2, and 3):
1. At the time the offense was committed the defendant was:
_ (a) on release pending trial for a felony;
_ (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.
DATED this l8th day of August , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
ana nstein
Assistant United States Attorney

Case 1:08-cr-00137-UNA

Document 2

Filed 08/18/2008

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Case 1:08-cr-00137-UNA

Document 2

Filed 08/18/2008

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