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

Case 1 5/2008 Page 1 of 3
{QP 6/
IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF DELAWARE I
_, UNITED STATES OF AMERICA, ) l
Plaintiff g I 1
I v. I i Criminal Action No. O X'] I-? "M
WHITNEY ANN WILSON, g
Defendant. g
MOTION FOR DETENTION HEARING
NOW COMES the United States and moves for the pretrial detention ofthe defendant, I
pursuant to 18 U.S.C. § 3 l42(e) and (i). In support ofthe motion, the United States alleges the
following: I
l. Eligibility of Case. This case is eligible for a detention order because case I
involves (check all that apply):
I ___ Crime ofviolence (18 U.S.C. § 3156) I
__ 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
_; 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
__ Safety of any other person and the community .

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3. Rebuttable Presumption. The United States willfwill not invoke the U i
` rebuttable presumption against defendant under § 3 l42(e). (lf 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
I __ 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,
i At first appearance
_ _X__ After continuance of _3__ days (not more than 3). . i
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 E
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
S residence. ·
_____ 3. The defendant may flee or pose a danger to any other person or the community.
2

Case 1:08-cr-00067-SLR Document 4 Filed O2/15/2008 Page 3 of 3
6. Other Matters.
‘ l
r
DATED this day ot` , 2008. .
Respectfully submitted,
COLM F. CONNOLLY
United St es Attorney E
BY: ; i ( ij j é
Seth M. Beausang
Assistant United States Attorney E
l
K

Case 1:08-cr-00067-SLR

Document 4

Filed 02/15/2008

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Case 1:08-cr-00067-SLR

Document 4

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Case 1:08-cr-00067-SLR

Document 4

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