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

Case 1 :08-cr—00037—JJF Document 3 Filed 02/1 1/2008 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-
IRA BLAND, i
Defendant. i
MOTION FOR DETENTION HEARING
I NOW COMES the United States and moves for the pretrial detention of the defendant,
pursuant to 18 U.S.C. § 3l42(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 (l8pU.S.C. § 3156)
. ___ Maximum sentence life imprisonment or death
___ 10+ year drug offense I
__ Felony, with two prior convictions in above categories
__ Minor victim I
_X_ Possession! use of firearm, destructive device or other dangerous weapon
___ Failure to register under 18 U.S.C. § 2250
L 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 Defendants appearance as required
__; Safety of any other person and the community

Case 1 :08-cr—00037—JJF Document 3 Filed O2/11/2008 Page 2 of 3
3. Rebuttable Presumgtion. The United States will not invoke the rebuttable
presumption against defendant under § 3 l42(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
___ 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
_; After continuance of ;__ 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
i residence. 3
____ 3. The defendant may flee or pose a danger to any other person or the community.

Case 1 :08-cr—00037—JJF Document 3 Filed O2/11/2008 Page 3 of 3
A 6. Other Matters.
DATED this 11th day 0fFBb1'u2LI'y, 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
A .. Martin Meltzer
· Special Assistant United States Attomey

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