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

Case 1:O8(@t00 ypD0cLrm&nt 7M 5F/il*e;i’,£)B/17/2008 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
Plaintiff l
v. ) Criminal Action N0. 08- Cf S'- UNK}
MATTHEW PALMER, )
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. § 3l42(e) and (t). ln 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):
A 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
_ 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):
L Defendant's appearance as required
A Safety of any other person and the community

Case 1:08-cr-OOO45—GlV|S Document 7 Filed O3/17/2008 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 (18 U.S.C. § 2252A(a)(2)).
_ 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 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. 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-OOO45—GIV|S Document 7 Filed O3/17/2008 Page 3 of 3
6. Other Matters.
DATED this I 7% day of [ijjkfj , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: E & é
Christopher J. Burke
Assistant United States Attorney

Case 1:08-cr-00045-GMS

Document 7

Filed 03/17/2008

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Case 1:08-cr-00045-GMS

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Case 1:08-cr-00045-GMS

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