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

Case 1 :08-cr-00127-GIVIS Document 4 Filed 07/24/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, I
v. i Criminal Action No. 08- [Z.§·•’ WV
JORGE MEI IAS, i
Defendant. I
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. Eligibiligg of Case. This case is eligible for a detention order because case
involves (check all that apply):
__ 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
__ Minor victim
_ Possession! use of firearm, destructive device or other dangerous weapon
Failure to register under 18 U.S.C. § 2250
L_ 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):
L Defendanfs appearance as required
_____m Safety of any other person and the community

Case 1:08-cr-00127—GlV|S Document 4 Filed 07/24/2008 Page 2 of 3
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), or a federal crime of terrorism, or a specified
offense t ) with minor victim
___ Previous conviction for "eligible" off`ense committed while on pretrial bond
4. Time For Detention Hearing. The United States requests the court conduct
the detention hearing,
_ At first appearance
i(_ After continuance of L 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.

Case 1:08-cr-00127—GlV|S Document 4 Filed 07/24/2008 Page 3 of 3
6. Other Matters.
DATED this 24* day of July , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attomey
BY:
Edward J. gééndrew
Assistant United States Attorney

Case 1:08-cr-00127-GMS

Document 4

Filed 07/24/2008

Page 1 of 3

Case 1:08-cr-00127-GMS

Document 4

Filed 07/24/2008

Page 2 of 3

Case 1:08-cr-00127-GMS

Document 4

Filed 07/24/2008

Page 3 of 3