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

i Case 1 :08-mj-00065 Document 3 Filed O3/25/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff; g
v. g Criminal Action No. 08-
JERMAINSE BARKSDALE, 3
Defendant. 3
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 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, destmctive device or other dangerous weapon
__ Failure to register under 18 U.S.C. § 2250
é 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):
i(__ Defendant's appearance as required · _ L Y I Hi
L Safety of any other person and the community L N. U w
..— ar I i
I

Case 1 :08-mj-00065 Document 3 Filed O3/25/2008 Page 2 of 3
_ rrorname cause to neneve defendant corrnnitted 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 _;_ days (not more than 3).
5. Temporagy 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):
l. 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-mj-00065 Document 3 Filed O3/25/2008 Page 3 of 3
6. Other Matters.
DATED this 25th day of March , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
’0bert J . Pr an /
Assistant U . d States Attorney

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