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

I - g p Case 1 :08-cr-00057-JJF i Document 3 Filed O4/07/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff, )
v. g Criminal Action No. 08- rm
DAWANN DIXON, )
Defendant. )
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. Eligibility 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
4X_ 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 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):
__;_ Defendants appearance as required
L Safety of any other person and the community

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3. Rebuttable Presumption. 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 ( J 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 continuance of _3__ days (not more than 3).
5. Temporary 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 2. The defendant is not a citizen ofthe 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—OOO57—JJF Document 3 Filed O4/07/2008 Page 3 of 3
6. Other Matters.
DATED this 7th day of April, 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: ,1 1. . / -/4%/44
' obert: J. Pret y
Assistant Unite tates Attorney

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