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

Case 1:08-mj—OOO38—l§;lL,QZ yjlgpdqugyrgjfw FQe_d__`Qé1,U2gp/Q/égage 1 of 3
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. n 1 IN THE UNITED STATES DISTRICT COURT
- .e FOR THE DISTRICT OF DELAWARE
5 UNITED STATES OF AMERICA, )
` Plaintiff, )
v. ) Criminal Action No. 08- 'ggrfvl
LAMOTTE STEVENSON, ) _
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 (f). In support of the motion, the United States alleges the `
following: l
l. Eligibilig of Case. This case is eligible for a detention order because case U
involves (check all that apply): _
l _ 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, destructive device or other dangerous weapon
_ Failure to register under 18 U.S.C. § 2250
1 ___)g__ 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):
__§___ Defendant's 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
i (check one or both): n
__ 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 E
offense ( J with minor victim i
_ Previous conviction for "eligible" offense committed while on pretrial bond I
4. Time For Detention Hearing. The United States requests the court conduct 1
the detention hearing, , i
I __ At first appearance
L_ After continuance of L days (not more than 3).
5. Temporary Detention. The United States requests the temporary detention of Z
the defendant for a period of ____days (not more than 10) so that the appropriate officials can i
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.
2 3. The defendant may flee or pose a danger to any other person or the community.

Case 1:08-mj—00038—UNA Document 3 Filed O2/11/2008 Page 3 of 3
6. Other Matters.
DATED this llth day of Februggg , 2008.
Respectfully submitted,
COLM F. CONNOLLY
United States Attorney
BY: { Q j é
Seth eausang
Assistant United States Attomey

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