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

Case 1 :08-cr-00098-SLR Document 3 Filed 06/05/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff g
v. g Case No. 08-98m
STEVEN DINEEN, g
Defendant. g
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 ofthe 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
___X_ Possession! use of firearm, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
_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 b'ql1_);_______ ____ _-__., -,
L Defendant's appearance as required I F I L E D
i(_ Safety of any other person and the community E i JUN 5 2033
E i
DISTRéCT 0;g£u7ygjij§_m________I

Case 1:08-cr-00098-SLR Document 3 Filed 06/05/2008 Page 2 of 3
3. Rebuttable Presumption. The United States will invoke the rebuttable
presumption against defendant under § 3142(e). (lf yes) The presumption applies because
(check one or both):
L 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 ( ) with minor victim
_ 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 a continuance of L days (not more than 3).
5. Temgorag 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 (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-00098-SLR Document 3 Filed 06/05/2008 Page 3 of 3
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: JB
Geofitey G ` er
Special Assistant United States Attorney

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