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

Case 1 :08-cr—OOO93-JJF Document 3 Filed 06/O2/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintifi 1
)
v. ) Case No. 08- 'F-/\
CONNELL KOGER, 1
Defendant. 1
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3 l42(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
__ 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
2 Failure to register under 18 U.S.C. § 2250
L Serious risk defendant will flee
__ Serious risk obstruction of j ustice
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 Defendant's appearance as required if 1 H T-112*1 D
;(_ Safety of any other person and the community 1 g 1
5 tllilé ? EGGS *

Case 1:08-cr—OOO93-JJF Document 3 Filed 06/O2/2008 Page 2 of 3
3. Rebuttable Presumgtion. The United States will not invoke the rebuttable
presumption against defendant under § 3 l42(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 ( ) 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
L After a continuance of L_ days (not more than 3).
5. Temporag; Detention. The United States requests the temporary detention of
the defendant for a period of ___days (not more than l0) so that the appropriate officials can
be notified since (check 1 or 2, and 3):
l. At the time the offense was committed, the defendant was:
2 (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 a11 offense;
2 (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—OOO93-JJF Document 3 Filed 06/O2/2008 Page 3 of 3
x4.u1•.u\.A I.|I»(.|¤I.\JD FXLLULLIUJ
BY: Z3 D A /*4*-***
Geoffr G er
Special Assistant United States Attorney

Case 1:08-cr-00093-JJF

Document 3

Filed 06/02/2008

Page 1 of 3

Case 1:08-cr-00093-JJF

Document 3

Filed 06/02/2008

Page 2 of 3

Case 1:08-cr-00093-JJF

Document 3

Filed 06/02/2008

Page 3 of 3